A London planning application almost always needs more technical reports than the same scheme would need elsewhere in England. The reason is structural: the London Plan sits on top of the National Planning Policy Framework and adds its own numeric targets for carbon, air quality, greening and drainage that all 33 boroughs must apply.
Five documents account for most of what a London borough will ask for at validation: a daylight and sunlight report, a flood risk assessment, an air quality assessment, an energy statement and a sustainability statement. This guide explains when each of these London planning reports is triggered, which policy drives it, what the assessor has to demonstrate, and what the draft London Plan published on 16 July 2026 is likely to change.
Which London planning reports do you actually need?
The honest answer is that the borough’s own validation list decides — but the triggers below cover the overwhelming majority of applications inside Greater London. The adopted London Plan (2021) remains the development plan for the capital until a new plan is adopted, so these are the policies your reports must answer today.
| Report | Typical London trigger | Policy hook | Technical standard |
|---|---|---|---|
| Daylight & sunlight | Development close to neighbouring windows, new flats, tall or dense schemes, or a neighbour objection about loss of light | London Plan D3 and D6; borough amenity policies | BRE BR 209 (2022); BS EN 17037 |
| Flood risk assessment | Any site in Flood Zone 2 or 3; sites of 1 hectare or more in Zone 1; areas with critical drainage problems | London Plan SI 12 and SI 13; NPPF | EA flood risk assessment guidance and template; CIRIA C753 for SuDS |
| Air quality assessment | Sites in or near an Air Quality Management Area, schemes generating traffic, and demolition or earthworks near sensitive receptors | London Plan SI 1 | EPUK/IAQM planning criteria; IAQM dust guidance v2.2 (2024); Defra LAQM.TG(22) |
| Energy statement | Major development (broadly 10+ homes or 1,000 m²+); many boroughs also ask for a proportionate statement on minor schemes | London Plan SI 2 | Part L 2021 baseline via SAP 10.2; Be Lean, Be Clean, Be Green |
| Sustainability statement | Most new dwellings and major schemes; commonly a validation item on minor applications too | London Plan G5, SI 5, SI 7; Environment Act 2021 | Biodiversity metric; Part G water calculator; Urban Greening Factor; BREEAM where required |
Before you commission anything, download the borough’s local validation list — it is the definitive specification. Our council planning portal finder and checklist generator will get you to the right document in a couple of clicks.
Daylight and sunlight: what London boroughs expect
London is the toughest daylight environment in the UK, and the reason is density. Schemes are routinely assessed both ways: the effect on existing neighbours, and the daylight received by the proposed units themselves.
The neighbour test is BRE BR 209 (2022): vertical sky component (VSC), no-sky line (NSL) and annual probable sunlight hours (APSH), with the familiar 0.8× rule flagging a material loss where a value drops below 80% of its former figure. The internal test is BS EN 17037, which sets target illuminance across a proportion of the room for a proportion of daylight hours. Policy D6 of the London Plan requires housing to achieve appropriate daylight and sunlight levels, and boroughs lean on that policy plus their own amenity standards when they refuse.
Two London-specific points matter. First, BR 209 Appendix F explicitly allows alternative, context-based targets in dense city centres — a well-argued appendix F case is often the difference between refusal and consent on a tight London site. Second, single-aspect north-facing flats remain the single most common cause of a poor internal daylight result. For more detail, see our guides to London Plan daylight standards in 2026, Appendix F alternative targets and single-aspect flats.
Flood risk assessment: the London trigger points
Check the flood zone before you do anything else. A site-specific flood risk assessment is required for all development in Flood Zones 2 and 3, for sites of one hectare or more even in Zone 1, and in areas with recorded critical drainage problems. You can confirm the zone in seconds on the Flood Map for Planning or with our free flood zone checker.
London adds two further layers. Policy SI 12 requires development to be safe for its lifetime and to take account of the defended tidal Thames — the Environment Agency’s Thames Estuary 2100 plan is the strategic context for anything behind the tidal defences, which means residual risk and breach scenarios get real scrutiny. Policy SI 13 requires a drainage hierarchy and sets an expectation of greenfield run-off rates, which on a constrained London plot usually means attenuation, blue roofs or rain gardens rather than a simple soakaway.
The commonest London failure is not fluvial at all: it is surface water. Large parts of the capital sit on impermeable clay with combined sewers, so an application can sit in Flood Zone 1 and still be refused on drainage. Read our guides to surface water flooding, flood zones 1, 2 and 3 and choosing SuDS for small sites.
Air quality assessment: Policy SI 1 and air quality neutral
Air quality is where London diverges most sharply from the rest of England. A large number of London boroughs have declared Air Quality Management Areas, several of them borough-wide, so the “is my site in an AQMA?” screening question that filters out most applications elsewhere filters out very few in London. Check yours with our AQMA postcode checker.
Policy SI 1 asks two things of major development. It must be at least air quality neutral — building and transport emissions benchmarked against GLA figures, not simply “better than the existing use” — and larger or masterplan-scale schemes are expected to produce an air quality positive statement showing how layout, massing and green infrastructure actively improve exposure. Our explainer on air quality neutral under Policy SI 1 sets out the benchmark method.
Alongside that, an assessment covers construction dust to IAQM guidance (v2.2, 2024), operational NO2 and PM2.5 concentrations against the objectives in Defra LAQM.TG(22), and exposure for any new residents introduced close to a busy road. Applications for homes fronting the A-road network in inner London are the ones most likely to attract an environmental health objection — see air quality assessments for new homes near busy roads.
Energy statement: the 35% target and the offset
For major development in Greater London an energy statement is not optional. Policy SI 2 requires a minimum 35% on-site reduction in regulated carbon emissions beyond Part L 2021, of which at least 10% for residential schemes and 15% for non-residential schemes must come from energy efficiency measures alone — the Be Lean stage — before any low-carbon heat or renewables are counted.
The statement has to work through the full hierarchy: Be Lean (fabric, form factor, airtightness, ventilation), Be Clean (heat networks and connection to any planned decentralised energy), Be Green (heat pumps and rooftop solar PV), with carbon savings reported at every stage against the SAP 10.2 notional building. Where the scheme cannot reach the zero-carbon target on site, the shortfall goes to the borough’s carbon offset fund; the GLA’s recommended price of £95 per tonne of CO2 applied over a 30-year period gives the familiar £2,850 per tonne figure. Estimate yours with our London carbon offset calculator, and see how carbon offset payments work.
Two practical notes. Post-2025 it is very hard to hit 35% with a gas boiler, so most compliant London schemes now assume an air source heat pump plus PV — the maths is in our heat pumps vs gas boilers guide. And commercial floorspace needs a BRUKL-based non-domestic assessment rather than SAP, covered in non-domestic Part L and BRUKL.
Sustainability statement: BNG, water, greening and BREEAM
The sustainability statement is the catch-all document, and in London it carries four distinct commitments.
- Biodiversity net gain. The mandatory 10% gain under the Environment Act 2021 applies in London as everywhere in England, but from 6 August 2026 most sites with a red-line boundary of 0.2 hectares or less are exempt, provided no priority habitat is affected — which removes a great many London infill plots from the regime. See the 0.2 hectare exemption and check yours with the BNG exemption checker.
- Water efficiency. New dwellings must be designed to 110 litres per person per day using the Part G water calculator — a routine planning condition across London. Our guide to passing the water calculator lists the fittings that get there.
- Urban greening. Policy G5 asks major development to meet an Urban Greening Factor score, and where a local plan sets no figure the London Plan targets of 0.4 for predominantly residential and 0.3 for predominantly commercial schemes apply as a minimum. Green roofs, rain gardens and substantial tree pits are what move the score — see the Urban Greening Factor explained.
- BREEAM and the referable extras. Boroughs commonly require BREEAM Excellent for non-residential floorspace above a threshold. Referable and major schemes also trigger a circular economy statement (Policy SI 7) and a whole life-carbon assessment, which sit alongside — not inside — the sustainability statement.
What does the draft London Plan (July 2026) change?
The Mayor published a draft of the new London Plan on 16 July 2026. Consultation closes at 5pm on 15 October 2026, an Examination in Public is expected during 2027, and adoption is anticipated in early 2028. The draft is roughly half the length of the current plan and leans harder on the NPPF for detail.
The critical practical point: the 2021 London Plan is still the adopted plan. Until the new plan is adopted, your energy statement still answers SI 2, your air quality assessment still answers SI 1, and your sustainability statement still answers G5. A draft policy carries limited weight, but it does signal direction — and on long-programmed schemes that direction is worth designing for now.
The changes most likely to reshape technical reports are:
- Policy GHR1 introduces Energy Use Intensity (EUI) and Space Heating Demand (SHD) standards with baseline and aspirational levels, and moves away from the current carbon offsetting approach — a shift from modelled regulated-carbon percentages towards absolute, measurable in-use performance.
- Policy GHR2 proposes a low carbon heat appraisal for major schemes, formalising the heat-source decision that currently sits inside the Be Clean stage.
- Policy GHR3 requires whole life-carbon evidence before a demolition decision is finalised, pushing retain-and-retrofit appraisal to the front of the programme.
- Policy GHR4 brings overheating, shading and passive design into masterplanning, with passive measures prioritised over active cooling — which ties daylight, glazing and Part O decisions together earlier than most design teams currently handle them.
Urban greening is also under review, with GLA work on Urban Greening Factor implementation expected to report during 2026.
How much do London planning reports cost and how long do they take?
Fees vary widely with scale and complexity, and London schemes sit toward the upper end of national ranges because of density, referable thresholds and borough-specific policy. Indicative UK figures — not quotes — look like this:
| Report | Smaller schemes | Larger or complex schemes |
|---|---|---|
| Daylight & sunlight | £500–£1,200 | £3,000–£8,000+ |
| Flood risk assessment | £300–£900 | £2,500–£12,000+ |
| Air quality assessment | £400–£1,500 | £1,500–£4,000+ |
| Energy statement | £250–£600 | £2,500–£5,000+ |
| Sustainability statement | £750–£1,200 | £3,000–£4,000+ |
Full cost breakdowns live in our dedicated guides: daylight report cost, flood risk assessment cost, air quality assessment cost, energy statement cost and sustainability statement cost.
On programme, commission in this order: flood risk and air quality screening first, because their findings can change the layout; daylight and sunlight next, once massing is fixed; energy and sustainability last, once the fabric specification and heating strategy are settled. Redoing an energy statement after a massing change is a common and entirely avoidable cost.
Frequently asked questions
Do minor applications in London need all five reports?
No. A single-dwelling infill will often need a flood risk assessment (if the zone triggers it), a daylight and sunlight report (if neighbours are close) and a proportionate sustainability statement. Energy statements are usually reserved for major development, though a number of boroughs ask for a short energy note on minor schemes.
Is an energy statement the same as an EPC?
No. An EPC rates a completed building; an energy statement is a planning document demonstrating a percentage carbon reduction against the Part L notional building before you build. See EPC vs energy statement.
Can one document cover energy and sustainability?
Some boroughs accept a combined energy and sustainability statement on minor applications. On major schemes keep them separate: the energy statement carries the SI 2 carbon arithmetic, and the sustainability statement carries BNG, water, greening and BREEAM.
What if my site is outside Greater London?
The five report types still apply, but the London Plan targets do not. Our UK-wide guide to planning application reports covers the national position, and daylight reports outside London explains what changes on the daylight side.
Does the draft London Plan mean I should wait?
No. Applications are determined against the adopted development plan, which is the 2021 London Plan. Design to today’s policy, but keep an eye on GHR1 and GHR3 if your scheme will still be in the system after 2028.
Key takeaways
- Five reports cover most London validation requirements: daylight and sunlight, flood risk, air quality, energy and sustainability.
- The London Plan (2021) remains the adopted plan — SI 1, SI 2, SI 12, SI 13, G5 and D6 are the policies your reports must answer today.
- Energy statements for major schemes must show 35% on-site carbon reduction beyond Part L 2021, with at least 10% (residential) or 15% (non-residential) from efficiency alone.
- Air quality neutral applies across the capital, and many boroughs are wholly or largely inside an AQMA.
- Urban Greening Factor targets of 0.4 (residential) and 0.3 (commercial) apply where a local plan sets no figure.
- From 6 August 2026, most sites of 0.2 hectares or less are exempt from mandatory 10% biodiversity net gain.
- The draft London Plan (16 July 2026, consultation to 15 October 2026) points towards EUI and space heating demand standards under GHR1 and whole life-carbon evidence before demolition under GHR3.
- Always check the borough’s local validation list — it, not the London Plan, is what gets your application registered.
How Fortress Associates can help
We produce all five reports for London applications. Our daylight and sunlight report service delivers BRE BR 209 (2022) and BS EN 17037 assessments in 4–5 working days with no advance payment.
Our flood risk assessment service produces a free, site-specific FRA using live Environment Agency data, following the EA’s FRA template and setting out a SuDS drainage strategy to CIRIA C753. Our air quality assessment service produces a free report from live official Defra, monitoring-network and DfT traffic data, screening AQMA status and assessing NO2, PM2.5, PM10 and NOx against EPUK/IAQM criteria.
Our energy statement service produces a free report built on the Part L 2021 / SAP 10.2 notional-building baseline and works through the full Be Lean, Be Clean, Be Green hierarchy, including the London Plan SI 2 35% target and carbon offset position for London sites. Our sustainability statement service produces a free report covering biodiversity net gain, water efficiency to 110 l/p/d, urban greening including the London Plan G5 Urban Greening Factor, and BREEAM where required.
You can also run the free planning tools yourself, or get in touch to talk through a London site. A summary of everything we do is on our services page.
Sources & further reading
- The London Plan (2021) — Greater London Authority
- Draft London Plan consultation (July–October 2026) — GLA
- BRE BR 209 (2022): Site Layout Planning for Daylight and Sunlight
- Flood risk assessment for planning applications — GOV.UK
- Flood Map for Planning — Environment Agency
- Defra UK-AIR: air quality data and background maps
- Institute of Air Quality Management (IAQM) guidance
- Approved Document L: Conservation of fuel and power — GOV.UK
- Understanding biodiversity net gain — GOV.UK
- National Planning Policy Framework — GOV.UK
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