Structuring an energy statement to the Be Seen stage
Be seen requires reported performance data for at least five years of operation. The metering strategy, the three reporting stages and how to secure a commitment that outlives the applicant.
The be seen energy monitoring London Plan requirement is the stage most applicants treat as a condition to worry about later, and then cannot discharge. Policy SI 2 of the London Plan 2021 adds a fourth step to the familiar be lean, be clean, be green hierarchy: schemes must monitor and report their actual energy performance after completion, through the Greater London Authority's reporting platform, for at least five years of operation.
That is a commitment running years past practical completion, made by an applicant who will probably have sold the building. Drafting it so it survives is a planning task, not a mechanical engineering one.
What the fourth stage requires
The first three stages are design calculations. Be seen is measurement.
In outline, a referable scheme reports three times: at planning stage, with the predicted energy demand and generation figures; at as-built stage, with the figures from the completed design and the installed systems; and then in use, annually, with metered data on actual consumption and generation. The reporting goes through the GLA's dedicated portal, using the data template the GLA publishes, and the figures are made public.
The scope is specified rather than open-ended. Reporting covers the regulated and unregulated energy use, on-site generation, and the performance of the heating and cooling systems, reported per the categories the template sets out. The GLA's guidance on energy monitoring sets the definitions, and reading it before writing the energy statement is the difference between a commitment you can honour and one you cannot.
Two points applicants get wrong. The obligation is on the development, so it persists through a sale and has to be passed on. And the in-use stage requires metered data of a granularity most buildings do not produce by accident, which brings us to the metering strategy.
Reporting at three stages
| Stage | What is reported | Timing |
|---|---|---|
| Planning | Predicted demand, generation and emissions by hierarchy stage | With the application, in the energy statement |
| As built | Figures from the completed design and installed plant, with the compliance output | Normally within a set period after practical completion |
| In use | Metered consumption and generation, annually | For at least five years of operation from first occupation |
The as-built stage is where the discrepancies surface. A scheme that promised an exhaust air heat pump and triple glazing, and delivered a different specification after value engineering, produces as-built figures that do not match the planning submission. The report has to explain the gap, which is uncomfortable but survivable. What is not survivable is having no as-built figures at all because nobody told the contractor to produce them.
Keep the modelling consistent across the three stages. The baseline conventions and the carbon factors used at planning stage should be stated so that the as-built comparison is like for like, a point covered in our note on thermal bridging detail at planning stage.
Metering strategy: design it at stage 3
In-use reporting needs data that only exists if the metering was designed for it. Specify the metering strategy during the technical design, not during commissioning.
What the strategy has to deliver:
- Separation of regulated from unregulated consumption, which means sub-metering by end use rather than a single incoming supply
- Landlord and tenant supplies metered separately, with a plan for access to tenant data that respects the tenancy agreements
- Generation metered at the inverter or generation meter, separately from net export
- Heat metering on any heat network connection or centralised plant, to a standard that allows efficiency to be derived
- Automatic meter reading with data logging at a useful interval, because manual monthly readings across a residential block will not be collected
- A nominated data owner with access rights written into the management arrangements
Residential schemes have the hardest problem. Getting in-use data from individual flats raises data protection questions and depends on resident co-operation, and a block where the managing agent has no access to consumption data cannot report. Resolve it in the lease and management structure at the outset, because retrofitting consent from 80 leaseholders is not a realistic plan.
Where plant selection affects the reporting, note that it also affects other assessments: refrigerant choice, flue heights and combustion plant all interact with air quality and noise, as our notes on refrigerant choice and global warming potential in planning and energy centre flue heights and air quality set out.
Securing the reporting in conditions and obligations
The planning mechanism matters because the obligation outlives the applicant's involvement.
A condition can require submission of the as-built report before first occupation, which works well: it is precise, enforceable and tied to an event. A condition requiring annual submission for five years after occupation is more awkward, because enforcement against a breach years later, on a building the applicant has sold, is unattractive to a council.
A section 106 obligation handles it better. The obligation runs with the land, binds successors, and can require the owner for the time being to submit the annual data, with the management company named as the responsible party where one exists. Some London boroughs use a financial mechanism alongside it, requiring a deposit returned on compliance or a payment where reported performance falls short of the commitment.
Three drafting points.
Name the responsible entity in a way that survives a sale: the registered proprietor for the time being, or the management company, rather than the applicant by name.
Define the data to be submitted by reference to the GLA template as it stands from time to time, rather than reproducing a version of it that will be superseded.
And set a realistic start point. The first full year of in-use data cannot begin until the building is occupied and systems are stable, so tie the first annual report to twelve months after a defined occupation threshold rather than to a calendar date.
Where schemes fail the comparison
The performance gap between designed and measured energy use is well documented in the industry, and the common causes are not mysterious.
Controls not commissioned properly, so heating and cooling run simultaneously or plant runs outside occupied hours. Ventilation systems with filters never changed, so fans run at higher duty. Heat networks with high distribution losses, where the measured efficiency of the system is far below the design figure. Unregulated loads larger than modelled, particularly in buildings with server rooms or heavy small power use. And simple metering faults, where a meter has read zero for eight months and nobody looked.
The honest point for a planning submission: the gap is normal, and a report that explains a shortfall with evidence is better received than one that quietly omits a year. The GLA's purpose in collecting the data is to understand real performance, not to catch people out.
Where soft landings or seasonal commissioning is proposed, say so in the energy statement, because it gives a reason for a first-year figure that improves later.
Writing a commitment that survives a change of contractor
The practical test of an Energy Statement is whether somebody who joins the project in two years can read it and know exactly what has to be delivered and measured.
That means stating the metering strategy in the statement, not just promising one. Listing the meters by end use and location. Naming the reporting template and the platform. Stating who holds the data and under what agreement. And setting out the as-built verification method, so the contractor's tender includes producing the figures rather than being asked for them afterwards.
Where the scheme is also pursuing a sustainability certification, align the evidence requirements so one set of commissioning data serves both. A BREEAM Pre-Assessment will call for much of the same metering and commissioning evidence, and duplicating it is waste.
One uncertainty worth naming. The London Plan is under review and GLA guidance on energy monitoring is updated periodically, including the template and the platform. Check the current version on london.gov.uk at the point of drafting rather than copying the commitment from a previous scheme, because a commitment written to a superseded template creates a condition nobody can discharge cleanly.
Draft your energy statement structure with PlanScope, then have the metering strategy reviewed by the engineer who will commission it.
PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. For specialist technical reports, qualified professional input may be required.
Frequently asked questions
What does the Be Seen stage of the energy hierarchy require?
Monitoring and public reporting of actual energy performance after completion, through the Greater London Authority's reporting platform, for at least five years of operation. It adds measurement to the three design stages of be lean, be clean and be green, and the figures are reported at planning, as built and then annually in use.
Why does in-use reporting need a metering strategy at design stage?
Because the data only exists if the meters were specified for it. Regulated and unregulated consumption have to be separated by end use, landlord and tenant supplies metered separately, generation metered at the inverter, and automatic meter reading with data logging installed. Retrofitting that after commissioning is expensive and often impossible.
Should Be Seen reporting be secured by condition or by section 106?
A condition works for the as-built report before first occupation, because it is tied to an event. Annual reporting over five years is better in a section 106 obligation, which runs with the land and binds the owner for the time being, naming the management company as the responsible party where one exists.
What causes a scheme to miss its predicted performance?
Controls that were never commissioned properly, so plant runs outside occupied hours or heating and cooling fight each other. Filters never changed, so fans run at higher duty. Heat networks with distribution losses far above the design figure. Larger unregulated loads than modelled. And meters that have read zero for months unnoticed.
How do residential blocks report in-use consumption?
Through landlord supplies and communal plant metering, plus whatever access to dwelling data the leases and management arrangements allow. Collecting individual flat consumption raises data protection questions and depends on resident co-operation, so the access rights and the nominated data owner need resolving in the lease structure at the outset.
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.