What a sustainability statement adds to an energy statement

An energy statement answers one question: how much regulated carbon the building will emit, and how the design reduces it. A sustainability statement covers everything else the local plan asks about environmental performance, which usually means water efficiency, materials, waste, biodiversity and greening, climate resilience, pollution and sometimes health and travel. Councils ask for both because their plan policies sit in different chapters, and the validation checklist mirrors the policies rather than the logic of the design.

The two documents overlap at exactly one point, the energy and carbon section, and that is where most submissions go wrong by repeating the same content twice in different words.

Why authorities ask for both

Local plans typically carry a climate change and energy policy with a carbon reduction target, and separately a sustainable design and construction policy covering water, materials, waste, overheating and biodiversity. Validation lists then require a document for each. In London the position is more structured, with the London Plan setting out energy, whole life carbon, circular economy and urban greening requirements that each have their own reporting expectations.

So the practical answer to "do we need both" is to read the two policies and the validation checklist, then decide whether one document with a clearly labelled energy section satisfies them. Many councils accept that. Some will not, and the cost of asking the case officer at pre-application stage is nothing.

Where a scheme is minor, one combined document is almost always accepted.

What sits in the energy statement

Keep it technical and keep it narrow. The Energy Statement should carry the modelled baseline against the current Part L target, the reductions achieved in sequence through fabric and demand reduction, then efficient supply, then renewable generation, with the resulting percentage improvement and the residual emissions.

Include the modelling outputs, the software and version, the assumed fabric values, the heating and ventilation strategy, the renewable capacity with roof layouts, and any district heating connection or safeguarding. Where a borough requires a carbon offset contribution for residual emissions, state the calculation method and leave the sum to be confirmed against the current charging approach.

Overheating belongs here or in a separate assessment, cross-referenced. Where the local policy requires a dynamic assessment, the results and the cooling hierarchy argument sit alongside the energy case rather than in the sustainability statement.

What a sustainability statement adds

The additional topics are where a sustainability statement earns its place:

1. Water efficiency, including whether the optional Building Regulations standard of 110 litres per person per day applies through a local plan policy, and the fittings specification that delivers it.
2. Materials, covering responsible sourcing, reused and recycled content, and where relevant a BREEAM or equivalent certification route.
3. Waste, distinguishing construction waste management from operational storage and collection arrangements.
4. Biodiversity and greening, including the biodiversity net gain position, green and brown roofs, planting and any urban greening requirement.
5. Climate resilience and adaptation, covering overheating, flood resilience measures, drainage and water reuse, and the resilience of the chosen heating strategy.
6. Pollution and amenity, covering light spill, noise from plant and construction, and air quality where the plan links it to sustainable design.
7. Health and wellbeing and, where policy requires, travel and active design.

Each one needs a commitment that can be conditioned. "Sustainable materials will be considered" is worthless. "All timber to be FSC or PEFC certified, with a schedule submitted before superstructure works" can be conditioned and discharged.

A short worked illustration of how the split works on a 40 unit scheme. The energy statement runs the modelling, reports a percentage improvement on the Part L target, sets out the air source heat pump strategy with the roof-mounted photovoltaic array, and calculates residual emissions. The sustainability statement then states the water target and fittings, the timber and insulation sourcing commitments, the construction waste targets and the bin store provision, the biodiversity net gain figure from the separate metric, green roof areas, the overheating conclusion by reference, and the flood resilience measures for the ground floor units. Nothing appears twice. That example is illustrative rather than a template for any particular authority's checklist.

Water efficiency deserves its own section

The optional tighter water standard applies only where a local plan policy invokes it, and it is then delivered through Building Regulations rather than through planning. Even so, councils routinely ask for the planning submission to confirm the design intent, because the policy lives in their plan.

State the target, the calculation method, the fittings schedule with flow rates, and any rainwater or greywater reuse. Where a rainwater system is proposed for drainage benefit as well, be careful about claiming the same volume twice for water saving and for attenuation.

Avoiding duplication between the two documents

Adopt one rule and apply it: each fact appears in one document, and the other cross-references it by section number.

Where the scheme also needs a Whole Life Carbon Assessment or a circular economy submission, those are standalone documents with their own methodologies, and the sustainability statement should summarise their conclusions in a paragraph each rather than reproduce them. Our note on circular economy statements: what the assessor checks covers what that document has to demonstrate on its own terms.

Structuring the two so they are read together

Lead the Sustainability Statement with a policy compliance table: every relevant local plan policy in the left column, the requirement in the middle, and where compliance is demonstrated in the right, by document and section. Officers write their reports from that table, and a submission that hands it to them tends to be reported accurately.

Then keep the order of sections the same as the order of policies, even where that produces an odd sequence. Consistency with the plan matters more than elegance.

Two practical points on the table itself. Quote the policy number and the policy title, because plans get replaced and an officer checking an old submission needs to know which version you read. And where the scheme does not comply with part of a policy, put that in the table with a cross-reference to where the justification sits, instead of omitting the row. Officers find the gap anyway, and a table with an honest row reads better than one that looks complete and is not.

Where a certification route is being used, a BREEAM Pre-Assessment gives the sustainability statement a credible spine, because the credits map onto most of the topics a policy covers. Be honest about which credits are targeted rather than aspirational, since the pre-assessment will be compared against the post-construction stage later.

One thing to watch on schemes with a long gestation. Part L and the wider regulatory position are moving, and a scheme designed against the current standard may be built under a later one. Say which standard the assessment used and on what assumption about the construction start, as our note on future homes standard: advising on schemes in progress explains.

PlanScope drafts both documents from the same project data, so the energy and sustainability sections stay consistent, and flags where site-specific figures are still needed.

For specialist technical reports, qualified professional input may be required. This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.