A planning report is judged on four things: whether it uses site-specific data, whether it applies the right standard, whether it states a result the case officer can act on, and whether it commits to mitigation the scheme can actually deliver. Everything else is presentation. Most reports that get sent back fail on the first or the last of those, not on the modelling in the middle.
This guide sets out what each of the five specialist planning reports must contain — daylight and sunlight, flood risk, air quality, energy and sustainability — section by section, so you can open a draft and tell whether it is ready to submit. If you are still working out which of them your application needs, start with our planning application validation checklist. This page is about what goes inside them.
What every planning report must contain
All five specialist reports share the same spine. A case officer, and any consultee they refer the report to, reads for the same seven things in roughly the same order. If a section is missing the report is not shorter — it is incomplete, and the answer comes back as a request for further information.
| Section | What it must show | Why the officer checks it |
|---|---|---|
| Site and proposal | Address, site area, red line boundary, a clear description of what is being built and the drawing numbers assessed | Ties the report to one specific application; a report that assesses a superseded drawing is worthless |
| Data sources and dates | Every dataset named, with the date it was obtained (flood map, background maps, monitoring data, weather file, habitat survey) | Proves the assessment reflects current mapping, not a figure carried over from an earlier job |
| Methodology and standard | The named guidance applied, the version, and any departure from it with a reason | Determines whether the numbers can be compared with the benchmark at all |
| Results | Numerical outputs in a table, room by room, receptor by receptor, or unit by unit — not prose | The officer must be able to see the pass and fail cases without recalculating anything |
| Mitigation and commitments | Measures that are drawn, specified or capable of being conditioned | Mitigation that cannot be built is a defect, not a wording point |
| Conclusion | A plain statement of compliance, partial compliance or shortfall, with the residual risk named | Officers write committee reports from conclusions; an ambiguous one invites an objection |
| Appendices | Calculation outputs, drawings, correspondence, survey sheets | Allows a consultee to audit the result rather than take it on trust |
The cost of getting this wrong is time. Cotswold District Council states that, on average, around 40% of the applications it receives are invalid — and an invalid application is not assessed at all until the missing material arrives.
What is inside a daylight and sunlight report?
A daylight report has two halves that are often confused. The first assesses the effect of your scheme on existing neighbouring windows; the second assesses the daylight received inside your own proposed rooms. Councils ask for one, the other, or both, and a report covering only half of what was asked for is the most common reason this one comes back.
The current standard is BRE BR 209 Site layout planning for daylight and sunlight (2022 edition), read alongside BS EN 17037 for internal provision. A joint BRE and RICS second edition is expected around the end of 2026; until it is published, BR 209 (2022) remains the guidance a report should cite.
A complete report contains:
- a description of the existing context, with a photographic record and the survey or model basis for neighbouring window positions;
- a schedule of every affected neighbouring window and the room it serves, identified on a plan;
- the numerical results for each BRE test, before and after, with the percentage change;
- internal daylight provision results for the proposed rooms where the council has asked for them;
- overshadowing of amenity space, where gardens or communal space are affected;
- a mitigation or justification section for any shortfall, and
- appendices with the model views, window schedules and calculation output.
| Test | What it measures | Benchmark in BR 209 (2022) |
|---|---|---|
| VSC | Vertical Sky Component — the skylight reaching the outside face of a window | 27%, or no less than 0.8 times the former value |
| NSL | No Sky Line — the share of a room's working plane that can still see the sky | Retain at least 0.8 times the former area |
| APSH | Annual Probable Sunlight Hours on windows within 90° of due south | 25% annual and 5% winter, or 0.8 times the former value |
| Overshadowing | Sun on ground across amenity space on 21 March | At least half the area receiving two hours of sun, or 0.8 times the former area |
| BS EN 17037 | Internal daylight provision by target illuminance | Target illuminance met over the assessed fraction of the room |
The 0.8 multiplier is where most disputes start — it is a relative test, so a window that already had poor light can lose very little in absolute terms and still fail. Our explainers on VSC, NSL and APSH and the 0.8 times rule cover the arithmetic, and what a daylight report is covers when one is triggered.
What is inside a flood risk assessment?
An FRA for an English planning application should follow the Environment Agency's flood risk assessment template (March 2025). The template is not decorative — consultees look for its sections by name, and a report that reorders or omits them is slower to review.
A complete FRA contains:
- the flood zone from the Flood Map for Planning, with the date the map was consulted;
- an assessment of all sources of flooding — river and sea, surface water, groundwater, sewer and reservoir — not just the mapped fluvial zone;
- the vulnerability classification of the proposed use and whether it is compatible with the zone;
- Sequential Test and, where required, Exception Test material, or a statement of why an exemption applies;
- climate change allowances applied to the design event, with the epoch and percentile stated;
- finished floor levels, with the design flood level and freeboard set out;
- safe access and egress, and a flood warning and evacuation position;
- a surface water drainage strategy — discharge rates, attenuation volume and the SuDS train to CIRIA C753; and
- residual risk, including what happens if the design event is exceeded.
The single most important change this year sits in that first bullet. On 28 May 2026 the Environment Agency updated the Flood Map for Planning to add surface water flood risk extents, climate change extents modelled to the upper-end allowance for the 2070s epoch, and banded depth data in seven bands from under 150 mm to over 2,300 mm. A site that was clear of mapped surface water risk before that date may not be clear now, and an FRA prepared on pre-May mapping can be out of date on the day it is submitted. See our note on the 2026 Flood Map for Planning update and the wider explainer on surface water flooding.
For minor householder extensions of less than 250 square metres in Flood Zone 2 or 3, the Environment Agency's standing advice sets out what a proportionate assessment looks like — it is a shorter document, but it still has to address floor levels and resilience. Our guides to Flood Zones 1, 2 and 3 and the Sequential and Exception Tests go further.
What is inside an air quality assessment?
An air quality assessment has two distinct phases, and a report that covers only one of them answers half the question. The construction phase deals with dust and, on larger sites, plant emissions. The operational phase deals with what the completed development emits and — increasingly the deciding issue — what the people living in it will be exposed to.
A complete assessment contains:
- a baseline: Defra background concentration maps for the relevant grid square, local monitoring data, and the site's Air Quality Management Area and smoke control area status;
- a construction dust risk assessment following IAQM guidance (version 2.2, January 2024), with the site classified for demolition, earthworks, construction and trackout;
- an operational assessment — traffic-generation screening against the EPUK and IAQM criteria, and dispersion modelling only where the screening indicates it is needed;
- an exposure assessment for new receptors introduced by the scheme, at the height and location where people will actually be;
- a comparison against the objectives in a table, receptor by receptor;
- a significance judgement made using the EPUK and IAQM descriptors, not an unexplained adjective; and
- a mitigation schedule that can be conditioned, and for London schemes an air quality neutral assessment under London Plan Policy SI 1.
| Pollutant | Objective or target | Averaging period |
|---|---|---|
| Nitrogen dioxide (NO₂) | 40 µg/m³ | Annual mean |
| Nitrogen dioxide (NO₂) | 200 µg/m³, not to be exceeded more than 18 times a year | 1 hour |
| PM10 | 40 µg/m³ | Annual mean |
| PM10 | 50 µg/m³, not to be exceeded more than 35 times a year | 24 hours |
| PM2.5 (England target) | 10 µg/m³ by 2040 under the Environmental Targets (Fine Particulate Matter) (England) Regulations 2023 | Annual mean |
Two directions of travel matter for a report written now. Defra published interim planning guidance on how the Environment Act PM2.5 targets should be considered in planning decisions, which is why exposure — not just compliance with the NO₂ objective — is increasingly the substance of the assessment. And the EPUK and IAQM land-use planning guidance is itself being revised, with member consultation on an exposure draft expected during 2026; a report should cite the version it has applied. Our posts on the pollutants planners care about and construction dust assessments expand on both phases.
What is inside an energy statement?
An energy statement is a carbon argument, not a specification list. Its job is to show a baseline, then show what each layer of the energy hierarchy takes off that baseline, in kgCO₂ per year, with the modelling that produced the numbers.
A complete energy statement contains:
- the policy context — Part L 2021, the local plan energy policy, and for London schemes London Plan Policy SI 2;
- a Part L 2021 baseline using the SAP 10.2 notional-building method for dwellings, or the equivalent non-domestic method for commercial floorspace;
- Be Lean — the fabric and services measures, with U-values, air permeability, thermal bridging and ventilation strategy stated as numbers;
- Be Clean — heat network connection, or a reasoned statement that no network is available or planned;
- Be Green — the low-carbon technologies, with heat pump type and capacity, and the solar PV array area and output;
- a carbon table showing regulated emissions and the percentage saving at each stage against the baseline;
- the shortfall against the target, and for London schemes the carbon offset contribution calculated at the borough's rate; and
- the SAP or SBEM output sheets as an appendix.
The timing question dominates every energy statement written in the second half of 2026. The Future Homes Standard package — including new editions of Approved Document L — was published on 24 March 2026 and comes into force on 24 March 2027 for new non-high-risk buildings, with a transitional period running to 24 March 2028. Part L 2021 therefore remains the compliance baseline for schemes being built out under existing permissions, while a scheme that will not start on site until after the transition needs to be designed to the new standard even though the current statement is written against the old one. A statement that does not say which regime it has assumed, and why, leaves that risk with the applicant.
Read which standard applies to your scheme and the energy hierarchy explained for the detail. Overheating sits alongside this rather than inside it — Approved Document O compliance is normally a separate overheating assessment.
What is inside a sustainability statement?
A sustainability statement is the broadest of the five and the easiest to pad. A good one is structured as a compliance argument against named policies, with an evidenced answer under each. A weak one is a set of aspirations.
A complete statement contains:
- a policy compliance table listing each relevant local plan and national policy with the response and the evidence reference;
- biodiversity net gain — the metric outputs, baseline and post-development units, the 10% figure, and the delivery route on site, off site or through statutory credits, or an evidenced exemption;
- water efficiency — the Part G Appendix A calculation demonstrating 110 litres per person per day where that optional requirement applies, with the fittings schedule that achieves it;
- urban greening — for London sites, the Urban Greening Factor score against London Plan Policy G5 with the surface schedule behind it;
- BREEAM — where a rating is required by policy, the pre-assessment tracker showing targeted credits and the weighted score;
- materials, waste and circular economy commitments; and
- climate resilience and adaptation, cross-referenced to the flood risk and overheating work rather than repeating it.
The biodiversity section changed materially on 6 August 2026. From that date, qualifying development on a red line site of 0.2 hectares or less is exempt from mandatory BNG provided priority habitat is not negatively affected; a new temporary development exemption applies to land reinstated within five years; the on-site-first hierarchy now applies only to major development, so minor schemes may consider on-site and off-site delivery together; and the self-build and custom-build exemption has been removed for applications made on or after that date. Applications submitted before 6 August 2026 continue under the previous rules. A statement that asserts an exemption without stating which one and evidencing the site area is the version that comes back.
Our related guides cover the 0.2 hectare exemption, the 110 l/p/d water calculation, the Urban Greening Factor and BREEAM in planning. Where a scheme needs the underlying calculations as standalone documents, they are separate pieces of work — see our water efficiency calculations, urban greening factor and BREEAM pre-assessment pages.
How long does each report take?
Turnaround varies far more with how complete the drawing pack is than with the report type. A scheme with a dimensioned site plan, floor plans, elevations and a red line boundary can be assessed immediately; one without them cannot be started.
| Report | Governing standard | Typical turnaround |
|---|---|---|
| Daylight and sunlight | BRE BR 209 (2022), BS EN 17037 | 4–5 working days |
| Flood risk assessment | NPPF and PPG, EA template (March 2025), CIRIA C753 | Automated report in minutes for qualifying sites |
| Air quality assessment | EPUK and IAQM criteria, IAQM v2.2 (2024), LAQM.TG(22) | Automated report in minutes for qualifying sites |
| Energy statement | Part L 2021, SAP 10.2, London Plan SI 2 | Automated report in minutes for qualifying sites |
| Sustainability statement | Environment Act 2021, Part G, London Plan G5, BREEAM | Automated report in minutes for qualifying sites |
For indicative fee ranges, see our cost guides for daylight reports, flood risk assessments, air quality assessments, energy statements and sustainability statements.
How to check a report before you submit it
Ten minutes with a draft catches most of what a case officer would send back. Work through it in this order:
- Do the drawing numbers and revisions in the report match the drawings you are submitting?
- Is every dataset dated — and is the flood mapping post-28 May 2026?
- Does the report name the standard and the version it has applied?
- Are the results in tables, with the failing cases visible rather than buried in prose?
- Is every claimed exemption identified by name and evidenced?
- Can each mitigation measure be pointed to on a drawing, or written as a condition?
- Does the mitigation physically fit the site as designed?
- Does the conclusion state compliance, partial compliance or shortfall in plain terms?
- Are the calculation outputs actually appended, not just referenced?
- Does the report answer the specific wording of the council's validation list entry?
Point seven is the one that costs applicants the most. A commitment the site cannot physically take — an attenuation tank where the root protection area sits, a PV array on a roof plane that does not exist — is a defect that surfaces at the discharge of conditions stage, long after permission.
Frequently asked questions
Can I use a template for a planning report?
A template helps with structure and nothing else. The Environment Agency publishes an FRA template precisely so that reports arrive in a predictable order, and following it is sensible. What a template cannot supply is the site-specific data, the modelling and the judgement — and those are the parts a consultee reads. A report that is a completed template with generic content is normally treated as no report at all.
What does a planning officer read first?
The conclusion, then the results table, then the mitigation. Case officers write their committee or delegated report from the conclusion of yours, so an equivocal conclusion tends to be recorded as an unresolved objection. Consultees — the Environment Agency, the lead local flood authority, the environmental health officer — go to the results and the data sources.
How current does the data in a report have to be?
Current at the date of submission, and demonstrably so. Flood mapping, background pollutant concentrations, AQMA boundaries and habitat baselines all change. The 28 May 2026 Flood Map for Planning update is the clearest recent example: an FRA quoting pre-update surface water mapping can be challenged on the day it lands.
Can one document cover energy and sustainability?
Some councils accept a combined energy and sustainability statement; many ask for two. Even where one document is accepted, the content must be separable — the carbon hierarchy and the SAP outputs on one side, biodiversity, water, greening and materials on the other. Check the validation list wording rather than assuming.
What happens if a report is inadequate rather than missing?
The application is usually validated but then stalls. The officer or consultee raises a holding objection, the eight or thirteen week clock runs down, and you are asked to agree an extension of time while the report is redone. That is generally slower than commissioning it properly at the outset.
Key takeaways
- All five reports share the same spine: site and proposal, dated data sources, named standard, tabulated results, deliverable mitigation, a clear conclusion and appended calculations.
- A daylight report must cover both effects on neighbours and internal provision if the council asked for both; BR 209 (2022) remains current, with a BRE and RICS second edition expected around the end of 2026.
- An FRA must address every source of flooding and must use the Flood Map for Planning as updated on 28 May 2026, including the new surface water and depth-band data.
- An air quality assessment needs both construction dust and operational phases, plus an exposure assessment for new receptors.
- An energy statement must state whether it is written against Part L 2021 or the Future Homes Standard, which comes into force on 24 March 2027.
- A sustainability statement must evidence any BNG exemption by name — the rules changed on 6 August 2026.
- Mitigation that the site cannot physically accommodate is a defect, not a drafting point.
How Fortress Associates can help
Fortress Associates prepares all five reports. Our daylight and sunlight reports are produced to BRE BR 209 (2022) and BS EN 17037, typically in 4–5 working days, with no advance payment. Our flood risk assessments are site-specific and free, built on live Environment Agency data and following the EA template, with a SuDS strategy to CIRIA C753. Our air quality assessments are free and use live official Defra background and monitoring data, DfT traffic counts and national AQMA boundaries, applying IAQM and EPUK criteria. Our energy statements are free and set a Part L 2021 baseline using the SAP 10.2 notional-building method before working through the full Be Lean, Be Clean, Be Green hierarchy. Our sustainability statements are free and cover biodiversity net gain, water efficiency, urban greening and BREEAM where policy requires it.
All of it is available across the UK — see the full list of planning and compliance reports, or get in touch with your drawings and postcode and we will tell you which of the five your application actually needs.
Sources & further reading
- BRE BR 209 — Site layout planning for daylight and sunlight (2022)
- RICS — Daylighting and sunlighting
- GOV.UK — Flood map for planning
- GOV.UK — Flood risk assessment for planning applications
- IAQM — Guidance library
- Defra UK-AIR — PM2.5 targets: interim planning guidance
- GOV.UK — Approved Document L, conservation of fuel and power
- GOV.UK — Biodiversity net gain guidance
- Greater London Authority — The London Plan
- GOV.UK — National Planning Policy Framework
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