England’s Local Climate Plans Leave Overheating Gaps

Only 53% of emerging English local plans require developers to provide a cooling or ventilation strategy, despite climate change appearing as an objective in most of the plans reviewed in a new national study.

The gap is wider in plans already adopted. The Royal Town Planning Institute’s review found that 27% of adopted plans contained the same requirement.

The review covered 475 local plans

The study examined 327 adopted plans and 148 emerging plans in England.

Local plans guide where development can occur and set policies used by councils when deciding planning applications. Their wording can influence site layout, building design, green infrastructure and the evidence developers must submit.

The report found that climate ambition was common at the broadest level.

Climate change appeared as an objective in 86% of adopted plans and 93% of emerging plans.

More detailed strategic climate policy appeared less often: 46% of adopted plans and 72% of emerging plans contained one.

The difference shows that naming climate change as an objective does not automatically create a complete set of measurable requirements for individual developments.

Cooling requirements remain uneven

A cooling or ventilation strategy can require a developer to explain how a building will avoid dangerous indoor temperatures.

The response can include orientation, external shading, glazing choices, insulation, ventilation, thermal mass and the management of internal heat gains.

Mechanical cooling can be part of the solution, but planning guidance often favours designs that reduce heat first rather than relying immediately on air conditioning.

Only 9% of adopted plans and 26% of emerging plans required a cooling hierarchy.

A cooling hierarchy normally prioritises passive measures before energy-intensive mechanical systems. It can help prevent a building from solving one climate risk by increasing electricity demand and waste heat.

The higher percentages in emerging plans indicate movement toward more detailed policy, but they also show that these requirements remain absent from many plans still being prepared.

Urban heat policy is more common than building strategy

The report found much stronger coverage of the urban heat-island effect.

Policies addressing urban heat appeared in 83% of adopted plans and 91% of emerging plans.

Urban areas can remain warmer than surrounding land because buildings, roads and other hard surfaces absorb heat while limited vegetation reduces shade and evaporative cooling.

Planning responses can include trees, parks, water features, green roofs, permeable surfaces and street layouts that support airflow.

Those measures are valuable at neighbourhood scale, but they do not necessarily establish how an individual home will remain safe during prolonged heat.

A plan can therefore acknowledge urban heat while leaving the building-level evidence requirement less specific.

Risk assessments are still uncommon

Only 11% of adopted plans and 28% of emerging plans were informed by a climate vulnerability or risk assessment, according to the RTPI review.

Carbon assessment was rarer. The report identified it in 2% of adopted plans and 7% of emerging plans.

A vulnerability assessment can identify which communities, buildings and services face the greatest exposure to heat, flooding or water stress.

Without that evidence, a climate policy may state an intention without showing where the most urgent risks are located or how limited adaptation funding should be prioritised.

The Town and Country Planning Association’s analysis described the wider issue as a gap between ambition and delivery.

The report does not establish that every plan without a named assessment ignored all climate evidence. It records whether the reviewed documents contained the policy features used in the study.

National Building Regulations already set a separate baseline

The local-plan findings do not mean new homes in England have no national overheating rules.

Approved Document O supports the Building Regulations requirement to limit unwanted solar gains and provide adequate ways to remove excess heat from new residential buildings.

The rules have applied to relevant new residential work in England since June 15, 2022.

Building Regulations and local planning policy perform different functions.

Building control examines compliance with national technical requirements. A local plan can address wider site conditions, neighbourhood heat, local vulnerability, green infrastructure and development-specific evidence.

A stronger local policy can therefore add context and planning requirements without replacing the national regulation.

The RTPI percentages should not be converted into a claim that every development in a plan without a cooling strategy is unlawful or unprotected. They measure the presence of specified local-plan policies, not the compliance result for each building.

Existing homes remain the larger adaptation challenge

The Climate Change Committee’s national adaptation assessment warned that 92% of existing homes could be at risk of overheating by 2050 without sufficient adaptation.

New-build standards can improve future housing, but most homes that people will occupy in the coming decades already exist.

Local planning still matters because today’s development decisions shape exposure for many years. Poor orientation, limited shade and heat-retaining public space can be difficult and expensive to correct after construction.

The committee also estimated that adapting the most vulnerable 30% of urban households could avoid a substantial share of projected heat-related mortality risk in the 2050s.

That evidence places ventilation and cooling policy inside a broader public-health and infrastructure problem rather than treating it as a question of comfort alone.

The report has methodological limits

The RTPI used an AI-assisted planning-document analysis tool to review a large national sample.

The report describes the results as an indicative snapshot and acknowledges that automated document analysis can produce errors. It also notes that local-plan status and wording can change.

The percentages are therefore best used to assess national policy patterns, not to make a definitive legal judgment about one council or development without reading the underlying plan.

The study still provides a useful comparison because it applies the same policy tests across hundreds of documents.

It shows that emerging plans generally contain more detailed climate provisions than adopted plans, while also identifying how far many remain from translating broad objectives into explicit operational requirements.

What changes after the report

The publication does not itself amend a local plan, Building Regulation or planning permission.

Councils would need to revise plan policies through their formal plan-making processes, while national government action would be required for changes to the Building Regulations or national planning framework.

Developers remain responsible for the requirements currently applicable to their projects.

The immediate change is evidentiary: policymakers now have a national estimate of how often climate language becomes a cooling strategy, hierarchy or risk assessment.

That record can be used during plan reviews, examinations and future national policy decisions.

TL;DR

• The RTPI reviewed 327 adopted and 148 emerging English local plans.

• Cooling or ventilation strategies appeared in 27% of adopted plans and 53% of emerging plans.

• National Approved Document O already sets a separate overheating baseline for relevant new residential buildings.

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