Sustainability Statement structure for a minor scheme
What belongs in a sustainability statement on a five to nine unit scheme, and what belongs in the energy statement instead, with a section order and a commitments table.
On a scheme of five to nine dwellings, a sustainability statement that repeats the energy calculations is wasted paper. The sustainability statement structure residential reviewers actually want covers what the energy statement does not: water, materials, waste, overheating, resilience, biodiversity and travel, each tied to the specific policy in the adopted local plan that asks for it. Twelve to twenty pages is normal. Fifty pages of generic text about climate change is worse than eight pages of site-specific commitments.
How it differs from the energy statement
The Energy Statement deals with regulated energy and carbon: the Part L 2021 target emission rates, the fabric first measures, the low carbon technology and the resulting emission reduction, with the SAP or SBEM outputs behind it. It answers a carbon question.
The sustainability statement answers everything else the local plan asks about environmental performance. On most minor residential schemes that means water consumption, construction materials and waste, overheating and adaptation, surface water, ecology, and access to services by means other than a car. Some councils ask for one document covering both, in which case the energy content becomes a chapter rather than a separate report. Read the validation checklist before deciding.
Water efficiency and the standard applied
Requirement G2 of the Building Regulations sets a baseline of 125 litres per person per day for new dwellings. Approved Document G also contains an optional requirement of 110 litres per person per day, which applies only where a planning condition imposes it, and many adopted local plans do exactly that.
Your statement needs three things on water: which standard applies, how the design achieves it, and the fittings schedule that proves it. A fittings-based calculation with flow rates for taps, showers, WCs and appliances is the accepted method, and the calculation should be attached rather than summarised. Where the local plan asks for rainwater harvesting or greywater reuse, say plainly whether it is proposed and, if not, why the fittings approach meets the target instead.
Materials, waste and circularity
Keep this section short and specific. What councils want to see on a minor scheme is responsible sourcing of timber under a recognised certification scheme, evidence that the main structural materials have been considered for their embodied impact, a commitment on recycled and reused content where it is realistic, and a site waste approach.
Naming the products helps. A statement that says timber will be certified, that the blockwork contains recycled aggregate and that the insulation has a published environmental product declaration is checkable. One that promises to consider sustainable materials during detailed design is not.
The Site Waste Management Plans Regulations 2008 were revoked, so there is no statutory plan requirement, but plenty of councils still ask for one by condition and a Site Waste Management Plan is the document that answers it. On a conversion or a scheme involving demolition, a pre-demolition audit identifying what can be reused or recycled on site carries more weight than a percentage target with no method behind it.
Full circular economy statements are a London Plan requirement for referable schemes rather than a minor development matter. On a nine-unit scheme, three paragraphs on reuse, adaptability and end-of-life are proportionate.
Overheating and climate resilience
Approved Document O governs overheating in new residential buildings, with a simplified method based on glazing area and opening area, and a dynamic thermal modelling route following CIBSE TM59. Which route you have taken belongs in the statement, along with the ventilation strategy and any mitigation such as external shading, reduced glazing to south and west elevations, or cross ventilation.
Where the simplified method has been used and the scheme has large south-facing glazing, expect a question. An Overheating Risk Assessment using the modelling route answers it properly, and on flats with single aspect and restricted openings it is usually the only credible route.
Resilience covers more than heat. Note the flood zone and the surface water position, the drainage approach, planting chosen for drought tolerance, and permeable surfacing where it is proposed. Two paragraphs, specific to the site, rather than a page on national climate projections.
Biodiversity and green infrastructure
The statement should cross-refer to the ecology evidence rather than duplicate it. Say what habitat is present, what the scheme does with it, and how the biodiversity gain requirement is being met, with the metric output and any Biodiversity Net Gain Assessment work referenced as the source.
Officers on small sites are looking for measures they can condition and check, so give them the detail. Add the practical items: native species planting, hedgerow retention with protected root zones, bat and bird boxes with locations and heights specified, hedgehog gaps in boundary treatments, and a management regime that says who cuts what and when. Specifying a 13 cm by 13 cm gap at the base of each garden fence line is the kind of detail that shows the document was written for this site.
Transport and accessibility content
This is the section most often padded. What is useful is short and factual. Give walking distances to the nearest bus stop, railway station, primary school, food shop and doctor's surgery, measured along the route rather than as a straight line. Then state the cycle parking provision against the local standard, including whether it is covered and secure, the car parking against the standard, and the electric vehicle charging provision.
Approved Document S has required charge point provision for new dwellings with associated parking since 2022, so state what is provided rather than treating it as an enhancement. Where the scheme is car-free or under-provided against the standard, that argument belongs here with the evidence, and on a scheme near capacity a parking survey may be needed to support it.
Pulling the document together
A structure that works on a minor residential scheme, in order:
- Site, proposal and the policies this statement responds to, listed by policy number from the adopted plan.
- Energy and carbon summary, cross-referring to the energy statement.
- Water efficiency, with the standard, the method and the fittings calculation.
- Materials and responsible sourcing.
- Construction waste and, where relevant, pre-demolition audit findings.
- Overheating and the compliance route taken.
- Climate resilience, drainage and surface water.
- Biodiversity, net gain position and green infrastructure detail.
- Transport, accessibility, cycle parking and charging provision.
- A commitments table listing each measure, where it appears on the drawings, and which condition could secure it.
That last table is the part reviewers remember. It takes an hour to build from the drawings and it shortens the officer's report. It gives the case officer draft condition wording and it stops measures disappearing between the statement and the construction drawings. Keep the wording consistent with the Design and Access Statement so that the two documents describe the same scheme.
One honest caveat on national policy. Approved Document L 2021 raised the standard for new homes and the Future Homes Standard has been the subject of consultation, with its final form and commencement to be confirmed. Check the current position on gov.uk at the time of writing rather than relying on a statement drafted last year, and say in the document which version of the Approved Documents the scheme has been designed against.
PlanScope provides AI-assisted draft reports for planning applications, including a Sustainability Statement drafted from your project information. Reports should be reviewed before submission. We do not guarantee planning approval.
Frequently asked questions
Is a sustainability statement the same as an energy statement?
No. The energy statement deals with regulated energy and carbon under Part L, with SAP or SBEM outputs behind it. The sustainability statement covers water, materials, waste, overheating, resilience, biodiversity and travel. Some councils accept one combined document, so check the local validation checklist before splitting them.
Which water standard should the statement use?
Requirement G2 sets 125 litres per person per day, and Approved Document G contains an optional 110 litre requirement that applies only where a planning condition imposes it. Many local plans require the tighter figure, so state which applies, show the fittings-based calculation and attach the fittings schedule.
How long should the document be on a small scheme?
Twelve to twenty pages is normal for five to nine dwellings, and shorter is often better. Length comes from site-specific commitments, calculations and drawings references rather than from general climate context. A long document that never mentions the site or the adopted plan policies gets read as a template.
Do minor schemes need a circular economy statement?
Generally no. Circular economy statements are a London Plan requirement for referable schemes. On a minor residential scheme, a few paragraphs covering reuse, adaptability and end-of-life handling is proportionate, along with a pre-demolition audit where existing buildings are being taken down.
What is the most useful part of the statement?
A commitments table at the end listing each measure, the drawing or calculation that evidences it, and the condition that could secure it. It gives the case officer draft condition wording and it stops measures being lost between the planning submission and the construction drawings.
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.