If you have been involved with any significant planning application recently, there’s a good chance that you have encountered (or soon will encounter) the dreaded energy statement.
Planning conditions for energy statements are now commonplace for both new and conversion schemes in the UK.
They effectively demand an energy performance over and above that required by the building regulations.
Applicants will usually need to show consideration of renewable technologies, centralised energy and extra energy efficiency measures.
Energy Statements & The London Plan
We spend a lot of time writing energy statements and many of these are for London schemes. The 32 London boroughs (plus the City of London) have set the bar very high through the adoption of the London Plan.
The London Plan is the overall strategic plan for Greater London, and it sets out a fully integrated economic, environmental, transport and social framework for the development of the capital to 2031. London boroughs’ local plans need to generally follow the London Plan, and its policies guide decisions on planning applications by councils and the Mayor.
The current version of the plan requires a 35% reduction in CO2 emissions over and above the building regulations 2013. This is measured and demonstrated by figures within your usual SAP Calculations or SBEM Calculations. Schemes may also need to achieve minimum performance against the Code for Sustainable Homes or BREEAM, depending on the proposed usage.
Due to the recent introduction of the NPPF (National Planning Policy Framework), local councils are now obligated to encourage development, if sustainable.
They are also free to set their own measures of sustainability and so the already established London Plan is being replicated all over the UK. Generally councils will set an extra CO2 reduction target of somewhere between 10-40%, and possibly require CfSH or BREEAM assessment too.
Some councils will set other objectives in addition to an energy Statement – for instance Bristol City Council requires all planning applications to include water reporting within the a broader sustainability statement, demonstrating that any surface water or flood risks are being mitigated.
Ealing Case Study
Even within London, different boroughs will require different things. The London Borough of Ealing for example has developed an especially forward thinking planning policy and as well as the usual energy statement, now require post construction monitoring. The onus is therefore on the developer to ensure all that of those impressive CO2 figures are actually delivered on completion.
Donna Skordili is Sustainability officer for Ealing Borough. “Monitoring should be an important aspect of all planning policies, as reliance on modelling software tools to calculate the energy demand of a building/development is not enough. Whilst all accredited energy performance modelling tools continue to evolve, it is generally acknowledged that they have limitations.”
Ealing Borough have implemented an independent, automated platform from Energence Ltd. Donna told BE, “We needed a solution which would be cost-effective to applicants/developers, would not create additional workload to Council officers and would provide us with the actual monitoring results. The system we have developed allows us to track and confirm compliance with our energy policies, and it will establish an evidence base about the performance of renewable technologies based on different development types in the borough”.
Ealing developments will need to monitor any renewable and low carbon energy generation proposed for a period of 3 years. The developer may use a pre-selected service provider to do this, where a minimal contribution will be secured through S106 legal agreement.
Alternatively the client may install independent equipment where monitoring data is sent to the Council’s provider on a daily basis.
In this case the applicant pays a fee directly to the Council’s provider for handling the data.
Energy Statements – What You Need
For any London Plan application we would expect to be providing at least 3 separate reports. These are:
- Sustainability / Energy Statement
- BREEAM / Code for Sustainable Homes pre-assessment report
- Part L Assessment (SAP or SBEM)
These three elements are entwined. For example, most of our clients are used to providing SAP Calculations for residential schemes to show building regs compliance. In the case of a current London Plan application, we will be using SAP to demonstrate not only that baseline performance, but also how an extra 40% improvement will be made.
The Energy Statement will need to outline in detail the proposed energy strategy including any energy efficiency measures. Importantly it must provide a full feasibility study of renewable technologies and how the scheme might make use of existing centralised heat and power networks, or provide new hubs for future networks.
Combined Heat and Power (CHP) units are encouraged and form a core part of the London Plan strategy, allowing future developments to ‘plug in’ and share generation locally.
As with any development, we can only repeat our usual mantra – “start early”. We are often drafted in at the last moment (usually a few days before a deadline) to produce an energy strategy. This is a recipe for a bad experience on all sides.
Get advice from your council early in the design stage – most planning officers will happily sit down at a pre-app meeting and then produce a letter detailing their requirements, outlining what you should be delivering with your planning application.
Even if you do not have pre application advice, any good assessor or consultant will be able to explore your local planning requirements and find out exactly what they need, ideally prior to pricing the work.
NOTE: we would recommend reading the Who Moved My Cheese and London Plan Update for important changes made in April 2015 – some of which affect the production of Energy Statements.