Energy Statements & Planning Energy Conditions
Frequently Asked Questions

An energy statement is a report showing that a development meets the energy and carbon dioxide (CO2) requirements set by the local planning authority.

Many councils have local plan policies asking new homes to do better than the minimum required by Building Regulations. For example, they may require lower CO2 emissions, or a proportion of energy from renewable sources. The energy statement sets out how the design meets that target, backed by calculations.

You may also see it called a sustainability statement, a carbon reduction statement or an energy strategy, depending on the council. Whatever the name, its practical purpose is the same: to get your planning application approved, or an energy-related planning condition signed off, so your project isn't held up.

You'll need one if your council's local plan requires it, or if your planning permission includes a condition about energy, CO2 or renewables.

There's no single national rule. It depends entirely on where you're building and the size of the development. Some councils only ask for energy statements on larger schemes, while others ask for them on developments of just one new home. Under the National Planning Policy Framework (policy PM13), councils can set energy standards above Building Regulations, as long as they're justified and tested for viability.

The easiest way to check is to look at your planning decision notice for any conditions mentioning energy, carbon, CO2, renewables or sustainability. If you're not sure what a condition is asking for, send it to us and we'll happily take a quick look free of charge.

No, but they're closely linked. The energy statement is built on the results of the SAP assessment.

  • A SAP assessment is the calculation that shows a home meets Part L of the Building Regulations, and it produces the EPC.
  • An energy statement uses the carbon and energy figures from the SAP assessment to show that the home also meets the council's planning targets, which are usually stricter than Part L.

Because the energy statement relies on the SAP figures, it makes sense to have both done together. The same model is used for both, so any changes made to meet the planning target are automatically reflected in the Building Regulations assessment, and you're not paying two companies to model the same building.

The key practical difference is that SAP and the EPC are about Building Regulations, while the energy statement is about planning. They're signed off by different parts of the council, often at different stages of the project.

The most common are a percentage reduction in CO2 emissions beyond Building Regulations, a percentage of energy from renewable or low carbon sources, or a combination of both.

  • CO2 reduction beyond Part L: the development has to produce a set percentage less CO2 than a home that only just meets Building Regulations. Targets of around 10% to 35% are common, depending on the council and the size of the scheme.
  • Renewable or low carbon energy: a set proportion of the development's energy, often 10% or more, has to come from sources such as heat pumps or solar panels.
  • London: under London Plan Policy SI 2, major developments (10 or more homes) need at least a 35% on-site reduction in CO2 beyond Building Regulations, with 10% of that coming from energy efficiency measures alone. The remaining emissions are offset through a payment to the borough. Many London boroughs also set their own targets for smaller developments.

Some councils, and the draft new London Plan, are starting to use different measures, such as total energy use or space heating demand per square metre. The details vary a lot, so it's always worth checking the exact wording of your local plan policy or planning condition.

We follow the "energy hierarchy" set out in the London Plan and used by many other councils: reduce the energy a home needs first, then supply it as efficiently as possible, then generate what you can from renewables.

  • Be lean: reduce energy demand through the building itself, with good insulation, windows and airtightness. We take a fabric-first approach where it's reasonable to do so.
  • Be clean: supply energy efficiently, for example by connecting to a local heat network where one is available.
  • Be green: generate energy on site from renewable sources. Heat pumps and solar panels are often part of the solution.
  • Be seen: for larger London schemes, monitor and report energy use once the homes are occupied.

There's usually more than one way to hit a target, and the costs can vary a lot. We model the options and recommend the most cost-effective combination for your project, bearing in mind what's practical for your site and design.

It depends on the council. Some allow the shortfall to be made up with a carbon offset payment, and some will accept a reasoned case for why the full target isn't feasible.

In London, for example, remaining emissions on major developments are offset through a payment into the borough's carbon offset fund, based on a price per tonne of CO2. The London Plan's recommended price is £95 per tonne, although boroughs can set their own.

Other councils may accept evidence that a particular measure isn't technically or financially practical for the site, such as solar panels on a heavily shaded roof. This is usually a last resort, and councils expect to see that the on-site options have been properly explored first.

In practice, most homes can meet typical targets with the right combination of measures, so it's worth exploring the options properly before assuming a shortfall.

As early as possible, and always before the deadline set in your planning condition. Some councils need it with the planning application itself; others ask for it later, as a condition of the planning permission.

Check the wording of your condition carefully. Some have to be signed off before any work starts on site (often called "pre-commencement" conditions), while others only need to be dealt with before the homes are occupied. Starting work before a pre-commencement condition has been discharged can put the planning permission at risk, so it's not something to leave to the last minute.

Getting the energy statement done early, alongside your design stage SAP assessment, also means the target can be designed in from the start, which is almost always cheaper than changing a design that's already been built.

Much the same as for a SAP assessment, plus the details of your planning requirements.

  • Your planning decision notice or the relevant local plan policy, so we know exactly which target applies
  • Scaled architectural drawings (floor plans, elevations, sections and a site plan)
  • The proposed specification: insulation, windows and doors, heating, hot water, ventilation and lighting
  • Any renewables already planned, such as a heat pump or solar panels

If the specification isn't finalised yet, that's fine. We can use the energy statement process to help decide it. When you accept a quote, you'll receive a full checklist of what's needed. Get an instant quote for your SAP assessments and energy statement together, or contact us to talk through your planning conditions.

Yes. Planning energy requirements exist in Scotland and Wales too, set through each council's local development plan.

In Scotland, many councils ask new developments to show that a proportion of their CO2 emissions is avoided through low and zero carbon generating technologies, such as heat pumps or solar panels. Welsh councils set their own energy and renewables policies through their local development plans.

As with England, the exact requirements vary from council to council. Where the requirement can be demonstrated using SAP results, we can help, wherever your project is in Great Britain.

Very likely, yes. The Future Homes Standard significantly tightens Building Regulations for new homes in England from 24 March 2027, and that changes the baseline many energy statement targets are measured against.

Because many planning targets are expressed as a percentage improvement on Building Regulations, a stricter baseline means a percentage target becomes harder to achieve. Councils are expected to review their policies over time. London, for example, is consulting on a new London Plan that moves towards different measures of energy performance.

Which rules apply to your project depends on when your application was made and when building work starts. If your project is likely to straddle the change, get in touch and we'll help you work out which standards and targets you're designing to.

Misconception Response
"An energy statement is the same thing as a SAP assessment or EPC." Not quite. The SAP assessment and EPC deal with Building Regulations, while the energy statement deals with planning. The energy statement is built on the SAP results, which is why it makes sense to do both together.
"Energy statements are only for big developments." Not necessarily. Some councils only require them for larger schemes, but others ask for them on developments of just one new home. Check your local plan and planning conditions.
"It's part of Building Regulations, so building control will deal with it." No. Energy statements are a planning requirement, discharged through the planning department. A home can pass Building Regulations and still fail to meet its planning energy condition.
"We can deal with the energy condition once we've started building." That can be risky. Some energy conditions have to be discharged before work starts, and starting early can put the planning permission at risk. Even where that's not the case, meeting the target is usually far cheaper when it's designed in from the start.
"We'll have to put solar panels on." Solar panels are often part of the most cost-effective solution, but they're not the only option. The right combination depends on the target, the design and the site, and we'll recommend what makes most sense for your project.