Active cooling overlooked in emerging local planning policy
UK – More than half of England’s emerging local plans require a cooling or ventilation strategy for new buildings, according to research from the Royal Town Planning Institute (RTPI) and the Town and Country Planning Association (TCPA).
The requirement appears in 53% of emerging plans, compared with 27% of adopted plans. However, only 26% of emerging plans require developers to follow a cooling hierarchy.
Such a hierarchy prioritises reducing solar gains and overheating through measures such as shading, appropriate glazing, natural ventilation, and building design before mechanical cooling is considered.
Steve Molloy, sustainability and commercial solutions manager at Daikin, said the report’s emphasis on passive measures risked overlooking the need for active cooling.
While these passive interventions are clearly important, in a warming climate where extreme weather events are becoming more frequent, they are unlikely to be enough on their own, particularly for existing building stock and vulnerable settings like care homes and hospitals
Steve Molloy, sustainability and commercial solutions manager at Daikin
Molloy cited the Climate Change Committee’s May 2026 report, which called for investment in cooling, including air conditioning and heat pumps, across key public services. The committee said active cooling may be necessary during intense or prolonged heatwaves, particularly in buildings occupied by people vulnerable to heat.
He also highlighted the limited scope of England’s overheating regulations. Part O of the Building Regulations applies to new residential buildings, but there is no equivalent Part O requirement covering commercial buildings or most existing and retrofit stock.
Molloy, said: “Without clearer policy support for this kind of dual-function technology, local authorities risk missing a vital piece of the climate mitigation puzzle.”
The report also found that energy standards using measures such as energy-use intensity and space-heating demand appear in 34% of emerging plans, compared with 3% of adopted plans.
The HVAC figures relate to new buildings or development generally and are not divided into domestic, commercial and industrial sectors. The clearest specifically residential figure is that emerging plans seeking net-zero operational-energy standards cover proposals for more than 1.1 million new homes.
The study examined 327 adopted plans already in force and 148 emerging plans at Regulation 19, submission or examination stage.
