If you’re developing in London, an Energy Statement is not just a formality, it’s a core planning requirement under the London Plan, and it directly affects approval timing, design decisions, and potential offset costs. At Energy Digest, we prepare London Plan–compliant energy strategies for architects, planning consultants and developers across Greater London, and we’ve seen first-hand how a strong submission saves both time and redesign cost.

This guide explains exactly what a London Plan Energy Statement is, when you need one, and how to approach it strategically to avoid GLA or borough pushback.

What Is a London Plan Energy Statement?

A London Plan Energy Statement is a formal planning document that demonstrates how your development reduces carbon emissions in line with the Be Lean, Be Clean, Be Green hierarchy. It uses SAP or SBEM modelling to calculate baseline emissions before applying a sequence of energy-saving measures.

The Greater London Authority (GLA) and individual boroughs expect your statement to show not just numbers, but a reasoned pathway, why design decisions were taken, how they align with policy, and what carbon reduction levels are realistically achieved onsite.

When Do You Need One?

You’ll be required to submit an Energy Statement if your project is:

• A major residential or commercial development (typically 10+ dwellings or more than 1,000 m² floor area)
• Located within Greater London
• Referred to the GLA or subject to borough-specific sustainability requirements

However, even smaller schemes are increasingly being asked for energy strategy documents depending on borough policy. We are now seeing local planning officers in boroughs like Lambeth, Hackney, Richmond and Hounslow requiring statements even for 1–9 dwellings where glazing levels or mixed-use elements trigger a sustainability review.

Understanding the Energy Hierarchy: Be Lean, Be Clean, Be Green

Under the London Plan, your energy strategy must follow this sequence:

Each stage must reference real specification values, not just generic policy wording. The GLA expect to see actual U-values, air permeability targets, system descriptions and photovoltaic outputs, not placeholders.

What a Strong Energy Statement Should Include

From experience, a compliant and well-received statement contains:

• Full SAP or SBEM carbon model outputs for each stage of the hierarchy

• Confirmed U-values, glazing specifications and targeted airtightness

• A clear position on gas boilers, if they are proposed, justification is required given the London Plan’s strong preference for all-electric, low-carbon heating

• Heat network feasibility review, boroughs expect a comment on whether connection is viable, even if ultimately dismissed

• Solar PV and heat pump yield projections with installed kWp and expected annual generation

• Carbon offset calculation at £95 per tonne of CO₂, if full zero carbon is not achieved onsite

• A signed energy strategy appendix aligned with the current GLA template layout

Carbon Offset Payments – What Developers Often Miss

Where a scheme cannot achieve 100% carbon reduction onsite, London boroughs require a carbon offset contribution. This is calculated at £95 per tonne of CO₂, based on the residual emissions after Be Lean / Be Clean / Be Green measures are applied.

At Energy Digest, we:

• Calculate the offset liability precisely based on verified modelling values
• Present it clearly in the statement, which avoids surprise fees at decision stage
• Advise on how to further reduce offset cost through targeted specification changes (often far cheaper than paying offset fees in full)

Part G Water Efficiency Calculations

Water usage is an increasingly important factor in sustainable design, and it's also a requirement under Approved Document G. For residential and mixed-use developments in London, you’ll need to show that your dwellings achieve a water consumption rate of no more than 105 litres per person per day. This is typically demonstrated through the use of water efficiency calculators that account for flow rates, fittings, and usage patterns.

Including Part G water calculations in your energy submission not only supports planning but helps reduce hot water demand, reinforcing the building’s energy-saving strategy under the 'Be Lean' approach.

Part O Overheating Assessments

Introduced in 2021, Approved Document O addresses the rising risk of overheating in new residential and mixed-use buildings. Developments must now undergo a detailed overheating risk assessment, either through a simplified method or using dynamic thermal modelling following CIBSE TM59.

Your energy strategy should demonstrate how passive design features, like orientation, glazing ratios, natural ventilation, and shading, have been used to mitigate overheating. These assessments are especially important in urban areas like London, where the urban heat island effect can exacerbate indoor comfort issues.

By including both Part G and Part O assessments, your submission presents a more complete picture of environmental responsibility, enhancing the credibility and compliance of your overall energy strategy.

You may also need to include a carbon offset payment calculation if zero-carbon targets aren't fully met onsite.

Why Early Energy Strategy Modelling Matters

Planning delays and redesign costs often arise not because the project is inefficient, but because the energy strategy wasn't modelled early enough. By running initial SAP/SBEM calculations before planning drawings are fixed, we can:

• Optimise carbon offset cost before the number is fixed in planning determination
• Flag heat pump sizing, glazing impacts, heat network feasibility and PV roof allocation before designs are locked
• Help architects avoid last-minute plant space issues (very common with all-electric systems)

Why Developers Choose Energy Digest for The London Plan Energy Statement

At Energy Digest, we don’t just issue a carbon model and a summary page. We act as your technical partner during design, making sure:

• Borough energy officers receive a clean, policy-aligned document that ticks every required box
• Offset costs are calculated transparently and minimised where possible
• You only go to planning once, with a strategy that will be accepted first time

Whether you’re submitting for pre-app, outline or full planning, we can prepare your statement with full SAP/SBEM modelling, Part G, Part O and offset cost reporting included, ready for direct submission to the GLA or local planning portal.