Who can write an energy statement for a planning application
The narrative can come from the design team. The calculations cannot. How accreditation levels limit the method, and the six checks on a statement you inherit.
The narrative part of an energy statement can be written by the design team. The compliance modelling inside it cannot. Calculations for dwellings have to be produced using the approved methodology by an assessor accredited under a government-approved scheme, and non-domestic calculations by a non-domestic energy assessor at the level matching the modelling method used. So the answer to who can write an energy statement is usually two people, and the question worth asking is which part each of them owns.
Architects get caught where the statement was assembled from a modeller's output without anyone checking whether the inputs match the drawings that went into the planning application.
What the statement has to demonstrate
An energy statement reports the design against the Building Regulations baseline and against any local policy target.
For dwellings that means the primary energy rate and emission rate against the targets generated from the notional building, plus the fabric energy efficiency figure. For non-domestic buildings it means the building emission rate against the target emission rate, produced by an approved calculation tool, with the compliance output appended.
On top of that, local policy may require a percentage improvement over the Building Regulations baseline, an energy hierarchy narrative working through demand reduction, efficient supply and renewables in that order, and in London a monitoring commitment. A statement that gives the percentage without showing the hierarchy stages that produced it will be sent back.
Set it out in the order the policy is written, which is what the Energy Statement covers section by section.
Accreditation schemes for assessors
Energy assessors are accredited through schemes approved by government, and their accreditation number and scheme are recorded with each lodged assessment. For new dwellings the relevant qualification is the on-construction domestic energy assessor route. For other buildings the non-domestic energy assessor qualification runs in levels, with the higher level required to use dynamic simulation modelling rather than the simplified method.
Two practical consequences follow. First, the level of accreditation limits the method, so a modeller qualified only for the simplified method cannot produce the dynamic simulation that a complex building or a Part O assessment may need. Ask which level before you appoint.
Second, the accreditation is personal. A practice cannot be accredited in the abstract, so the statement should name the individual who produced the calculations along with the scheme and the number. Naming the author is good practice across all planning documents, and why a planning report should name its author and date applies with particular force to a document that will be compared against a building control submission two years later.
Modelling tools and their limits at planning stage
The approved methodologies are compliance tools, and they are often read as though they were predictions. They are not.
The domestic methodology uses standardised occupancy, standardised internal temperatures and standardised hot water demand, so its output is a comparison between a design and a notional equivalent rather than a forecast of consumption or bills. The non-domestic tools behave similarly unless a full dynamic model with realistic operating profiles is built, which is a different and larger exercise.
Three limits matter when an officer asks what the figures mean:
- the output covers regulated energy only, so unregulated loads such as appliances and small power sit outside it unless policy requires them separately
- the comparison is against a notional building generated by the methodology, so the baseline moves when the Approved Document changes
- overheating is a separate assessment under Part O, using either the simplified method or dynamic thermal modelling, and a good energy result can sit alongside an overheating failure
That last point is the one that costs schemes money. Glazing areas and orientation chosen to improve the energy figure can push the building into an overheating problem, so run both assessments together and set the results out in the Overheating Risk Assessment, which councils expect from a suitably qualified author.
Where the assessment is done too early
A planning-stage model is built on a design that is not finished. Glazing ratios, construction build-ups, services selections and the renewables layout are all provisional, and the modeller fills the gaps with assumptions.
The risk is that the resulting percentage becomes a planning commitment. A condition tying the development to the submitted energy statement locks in a figure derived from assumptions that the detailed design may not support, and the remedy afterwards is a section 73 application or a variation, which costs more than getting the assumptions right would have.
Two defences are worth building in. Record the assumptions explicitly in a table within the statement, so that what was committed is identifiable rather than buried in a model. And model a sensitivity case showing the effect of the most likely design changes, which gives the project room to move without breaching the condition.
Where the scheme is at outline stage with reserved matters to follow, say so and set out the strategy rather than a precise figure, with a mechanism for the figure to be confirmed at reserved matters.
Carrying assumptions into building control
The planning-stage statement and the building control submission are different documents produced at different times, often by different people, and the gap between them is where commitments quietly disappear.
Value engineering is the usual cause. A specification change from a high performance glazing unit to a standard one, a reduction in photovoltaic area because the roof is needed for plant, or a change of heat pump model with a lower efficiency each move the result. None of those is unusual, and none of them is announced to the planning authority.
Keep a single schedule of the committed inputs, hold it with the design team rather than with the modeller, and check it at each design review. Where a change breaks the commitment, deal with it through the authority before completion rather than at the point someone compares the as-built certificate with the condition.
Reviewing an inherited statement
When a statement arrives from a previous team, work through it in this order:
- Identify the calculation tool and its version, and the edition of the Approved Document the baseline was generated from. An older edition means the percentage improvement is not comparable with current policy.
- Find the assessor's name, accreditation scheme and number, and the date of the calculation.
- Check whether the headline percentage is regulated emissions only, and whether local policy requires more than that.
- Read the input assumptions against the submitted drawings. Glazing areas, U-values, airtightness, thermal bridging route and renewables area are the ones that diverge most often.
- Check the renewables assumptions for plausibility. Photovoltaic output assumed from a roof area that is also carrying plant, lift overrun and a terrace is the commonest error.
- Check whether an overheating assessment exists and whether it used the same geometry.
Where the statement fails on any of those, re-modelling is usually faster than defending it. A statement that nobody on the current team can explain is a liability at the condition discharge stage.
Appointment timing in the design programme
Appoint the assessor early enough to influence the design and late enough that there is a design to model. In practice that means during concept design for a strategy and an early feasibility run, then a full calculation once the fabric and services strategy is settled, ahead of the planning submission.
Then plan for two more appointments. An as-designed calculation for the building control submission, reflecting the developed design. And an as-built calculation at completion, which is what produces the certificate the planning condition may require.
Budget for all three rather than one, and put the sensitivity run in the first appointment. The modelling fee is a small fraction of the cost of a design change forced by a condition nobody checked. Where you want an independent view on an inherited statement, PlanScope's professional directory is one route for requesting a review and recording its status.
PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. Compliance calculations must be produced by an accredited assessor, and this article is general guidance rather than advice on a particular scheme, so check requirements with your local planning authority or a qualified professional. Enter your postcode on PlanScope to see which reports your project is likely to need.
Frequently asked questions
Does an energy statement have to be written by an accredited assessor?
The compliance calculations do. Assessments for new dwellings must be produced through the approved methodology by an assessor accredited under a government-approved scheme, and non-domestic calculations by a non-domestic energy assessor at the level matching the method used. The narrative and policy sections can be prepared by the design team.
Why does the assessor's accreditation level matter?
Because it limits the method available. The higher non-domestic level is required for dynamic simulation modelling rather than the simplified calculation, and a complex building or a Part O overheating assessment may need that method. Ask which level the individual holds before appointing, since accreditation is personal rather than held by a practice.
Does the modelled figure predict energy bills?
No. The approved methodologies use standardised occupancy, internal temperatures and hot water demand, so the output compares a design against a notional equivalent generated by the methodology. It also covers regulated energy only, leaving appliances and small power outside unless local policy requires them to be reported separately.
What happens if the design changes after permission?
If a condition ties the development to the submitted statement, a change that breaks the modelled result needs to be dealt with through the authority, usually by a section 73 application or a variation. Keep a schedule of committed inputs with the design team and check it at each design review rather than at completion.
How do I check a statement produced by a previous team?
Identify the tool and version and the edition of the Approved Document the baseline came from, find the assessor's name and accreditation number, confirm whether the percentage is regulated emissions only, compare the input assumptions against the submitted drawings, test the renewables assumptions against the available roof area, and check the overheating assessment used the same geometry.
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.