Energy statements for industrial and logistics units
A logistics shed has low regulated energy, huge process loads and a roof the size of a field. Energy statements written for housing miss all three.
An Energy Statement for a distribution shed is a different document from an energy statement for a block of flats, and the mistake most often made on logistics schemes is submitting the second one with the floor areas changed. A warehouse has low occupancy, enormous volume, a roof the size of a small field and process loads that dwarf its regulated energy. The policy framework it is assessed against was mostly written with housing in mind.
Approved Document L Volume 2 of the Building Regulations covers buildings other than dwellings, and the 2021 edition raised the standard for new non-domestic buildings by around 27 per cent in carbon terms against the 2013 edition. That is the compliance baseline. Local policy then asks for more.
What the authority is testing
Three things, usually in this order. Whether the building meets or betters the Building Regulations baseline by the margin the adopted local plan requires. Whether the energy hierarchy has been applied in sequence rather than asserted. And whether whatever is promised can be secured by a condition that an officer can later check.
The hierarchy is "be lean, be clean, be green", with a fourth stage, "be seen", added in London for post-occupancy monitoring. Applying it in sequence means demand reduction first through fabric and services efficiency, then efficient supply, then renewables. Jumping straight to a roof full of panels and a headline percentage reads as retrofitting the answer, and experienced officers treat it that way.
Compliance modelling for a shed is done in SBEM for simple cases and dynamic simulation where the geometry, glazing or servicing is more involved. The output that officers are increasingly asked to look at is the BRUKL document, which sets out the notional building comparison. That comparison is the source of most of the confusion in this field, and the mechanics are worth understanding before you argue about percentages: the notional building and why baselines confuse officers is a problem that shows up on non-domestic schemes even more than on housing, where the three Part L targets for a new dwelling at least follow a familiar pattern.
Where the carbon sits in a logistics building
Regulated energy in a warehouse is modest. Lighting, a small amount of space heating, domestic hot water in the welfare core, and the servicing of the office element. A big part of the building is a tall volume that is heated to a few degrees above freezing, if at all.
Unregulated energy is the opposite. Materials handling equipment, conveyors, automation, battery charging for forklifts, refrigeration in a chilled or frozen facility, and increasingly fleet vehicle charging. On an automated facility the process load can be several times the regulated load. Part L does not count it. Several local policies, and the London Plan reporting format, do ask for it to be reported.
Two practical consequences. First, a percentage improvement against a regulated-energy baseline can look impressive while the building's actual consumption is dominated by something the calculation never saw. Say so in the statement rather than leaving the officer to spot it. Second, the single largest carbon decision on a cold-store scheme is the refrigeration system and its refrigerant, which sits outside the energy statement unless you put it there.
Fleet charging deserves its own paragraph in the statement, with the grid capacity secured and the phasing explained, because it is routinely dealt with through electric vehicle charging conditions that assume a car park rather than an HGV yard.
Fabric and air permeability on a very large envelope
Portal frame buildings fail on the details. Thermal bridging at the eaves, the base of the cladding, around dock levellers and across large sliding or roller doors. Air permeability testing on a building of this volume is a logistical exercise in its own right, and the tested figure is what the as-built calculation uses.
The dock itself is the weak point. Every door opening is a hole in the envelope, and on a cross-docked facility the doors are open most of the working day. Modelling an air permeability figure that assumes a sealed box, then operating a building with forty doors cycling, produces a gap between the energy statement and reality that nobody benefits from. Where the operator is known, describe the operating pattern.
Roof and wall U-values on sheds are usually better than the notional building because insulated composite panels cost little per square metre relative to the alternatives. That makes fabric the easiest place to bank a real improvement, and it is worth taking it there rather than on glazing, which on a shed is a small area with large consequences for overheating in the office element.
Shell and core, and the tenant problem
Most speculative logistics units are consented as shell and core, with the fit-out and sometimes the office layout left to an occupier who does not exist yet. That creates a genuine difficulty for an energy statement, because the things that determine performance are not in the application.
The workable approach is to split the statement explicitly. Set out what the landlord's base build delivers and commit to it. Then set out the design assumptions for the fit-out, the provision made for them, the infrastructure left in place, and the mechanism by which an incoming occupier's fit-out will be assessed. Several authorities will accept a condition requiring a fit-out energy strategy at the point a tenant is known, which is a better outcome than a base-build statement that quietly assumes a fit-out it cannot control.
Do not promise occupier behaviour. A statement that claims a tenant will procure renewable electricity is unenforceable and officers know it.
Solar on the roof, structurally and electrically
The roof is the obvious asset and there are two constraints on using it.
The structural one. Retrofitting panels to a frame designed without them means checking the purlins and the main frame for the additional dead load and wind uplift, and a frame designed with a PV allowance costs more in steel. Decide at design stage, not at discharge of conditions, because the structural uplift is not something a condition can conjure.
The electrical one. A large array needs a grid connection that can accept export, or a load profile that can absorb it on site. Distribution network operator capacity in logistics locations is often the binding constraint, and connection offers come with timescales measured in years in constrained areas. An energy statement that promises an array without a connection position is a statement with a hole in it.
Where the array is sized to the building's own demand rather than the roof's capacity, say that, and explain the demand profile. A warehouse with daytime automation and a south-facing roof is close to an ideal match. A dark store running overnight is not.
| Element | Counted in Part L | Usually in local policy | Who controls it |
|---|---|---|---|
| Lighting and controls | Yes | Yes | Base build |
| Space heating and hot water | Yes | Yes | Base build |
| Fabric and air permeability | Yes | Yes | Base build |
| Process and automation loads | No | Reported in some policies | Occupier |
| Refrigeration and refrigerant | Partly | Increasingly | Occupier or fit-out |
| Vehicle and plant charging | No | Yes, by condition | Base build provision, occupier use |
London and the offset payment
London Plan 2021 Policy SI 2 requires major development to be net zero-carbon, with a minimum on-site reduction beyond the Building Regulations baseline and a cash-in-lieu offset payment to the borough for the residual. Greater London Authority energy assessment guidance sets the current baseline, the reporting template and the "be seen" monitoring requirements, and it has been updated since the Plan was adopted, so take the figures from the live guidance rather than from an older statement.
Referable schemes also need a whole life carbon assessment and a circular economy statement. On a steel-framed shed with a large concrete slab, embodied carbon is where the real number is, and a Whole Life Carbon Assessment prepared to the RICS methodology will show the frame, substructure and slab dominating. That finding usually surprises nobody who has priced the steel.
Securing it and proving it
Ask for a condition that names the approved energy statement and requires an as-built verification against it, rather than an open requirement to achieve a percentage. Verification evidence is the as-built BRUKL, the air permeability test results and the commissioning records for the renewable installation.
Where the scheme includes a fit-out stage, agree the trigger for the fit-out strategy at the same time. Leaving it undefined means arguing about it when the tenant is signed and the programme is fixed, which is the worst moment available.
This is general guidance, not legal advice. Check the position with your local planning authority or a qualified energy assessor before relying on it.
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Frequently asked questions
Which Part L applies to a warehouse?
Approved Document L Volume 2, which covers buildings other than dwellings. The 2021 edition raised the standard for new non-domestic buildings by around 27 per cent in carbon terms against the 2013 edition. Compliance is demonstrated through SBEM for simple buildings or dynamic simulation modelling where the geometry or servicing is more involved.
Do process and automation loads count towards the energy statement?
Not under Part L, which assesses regulated energy only. Several local policies and the Greater London Authority reporting format do ask for unregulated energy to be reported. On an automated or chilled facility the process load can exceed the regulated load several times over, so state it rather than leave the officer to notice the gap.
How do you write an energy statement for a speculative shell and core unit?
Split it. Commit to what the landlord's base build delivers, then set out the fit-out design assumptions, the infrastructure provided and the mechanism for assessing an occupier's fit-out. Many authorities accept a condition requiring a fit-out energy strategy once a tenant is known, which is more honest than assuming a fit-out you cannot control.
What stops a large roof solar array going ahead?
Two things. The frame has to carry the additional dead load and wind uplift, which has to be designed in rather than added at condition stage. And the distribution network operator has to be able to accept export, or the site has to absorb the generation itself. Connection offers in constrained logistics locations can run to years.
Does a logistics scheme in London need a whole life carbon assessment?
Referable schemes do, alongside a circular economy statement, under the London Plan 2021. On a steel-framed shed with a large concrete slab the embodied carbon in the frame, substructure and slab usually dominates the whole life result. Prepare it to the RICS whole life carbon methodology and check the current Greater London Authority guidance.
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.