Manchester Local Plan: What It Means for Building Compliance

Manchester City Council are creating a Manchester Local Plan. It covers everything from housing to heritage and sets out the regions targets for the next 15 years. The main focus is Net Zero by 2038 and Manchester’s buildings are a big part of the plan. Currently in draft form and under consultation, we’ve picked out what’s interesting for architects, developers and what it means for building regulations compliance.

The Manchester Net Zero Carbon Building Standard is NOT The Future Homes Standard

It’s a bit of a mouthful, so we’ll refer to the Manchester Net Zero Carbon Building Standard as MNZCBS throughout this article. When we first saw it, we thought it was just a local rebranding of the Future Homes Standard (FHS). It is not. The FHS, due later this year will use percentage based increases on current Part L notional building standards. However, the MNZCBS has been specified in its draft to use targets closely aligned with LETI and Passivehaus principles, typically much more stringent than Part L targets.

It will not be assessed in the same way either.

Two Assessments, Two Approvals

The FHS will use SAP Calculations initially (an interim SAP 10.3 methodology) and after brief transition period, SAP will be left behind and the Home Energy Model (HEM) will take it’s place, fully integrating into the FHS.

Both SAP and HEM will use metrics like the Dwelling Emission Rate (DER), Dwelling Primary Energy Rate (DPER) and the Dwelling Fabric Energy Efficiency (DFEE) for Part L compliance.

In Manchester new dwellings will also need to have a second compliance assessment, due at design stage, to satisfy these new local planning regulations. These new homes will be targeted to reach 15-20 kWh/m²/yr for their space heating demand and a total energy use intensity of 45 kWh/m²/yr. Each new home will need to be modelled using Passive House Planning Package (PHPP), Design for Performance, NABERS UK Design or CIBSE TM54. This is completely different to how SAP works and how HEM will work.

The draft policy doesn’t specify a threshold for residential development. As written it would apply to single dwellings as well as major schemes. Whether that survives consultation and how rigorously it’s enforced on smaller projects remains to be seen.

Non Residential Manchester Building Compliance

Manchester has specified two types of non residential developments in the Manchester Local Plan.

A minor development, classified as under 1000m², would not need to reach the MNZCBS as long as the building:

• Achieves a ‘Very Good’ BREEAM rating, or
• Meets the standards required by building regulations at the time of construction.

The guidance is unclear. The practical effect appears to be that minor non residential development is exempt from the stricter MNZCBS targets, just pass Building Regs as normal. BREEAM Very Good is offered as an alternative route, likely for projects already pursuing that certification.

For larger non-residential projects (1,000m² and above), including refurbishments and conversions, the full MNZCBS applies:

• 40 kWh/m²/yr space heating
• 70 kWh/m²/yr total energy use

Compliance would be demonstrated using TM54, NABERS or Design for Performance.

Viable ‘Get Out’

Policy ZC2 of the Manchester Plan includes flexibility where targets cannot be met. The two clauses are:

• Practicality
• Financial Viability

Using the energy hierarchy approach, each development must show that emissions have been reduced to the lowest practical level and carbon offsetting only becomes an option after demonstrating that further on-site measures are unfeasible.

Typically, within Building Regulations, consequential improvement measures use a 15-year simple payback test to determine viability. The Manchester Local Plan offers no such definition. This could mean this detail is still being developed, or viability will be judged at the planning officer’s discretion.

What About Overheating?

The London Plan set a precedent by requiring CIBSE TM59 overheating assessments at planning stage. Major residential developments in London must demonstrate compliance with TM59 criteria before planning approval, not just at Building Control.

Manchester hasn’t followed this approach. The Local Plan mentions overheating only at a high level – design through “layout, orientation, form and massing” and use of green infrastructure for cooling. There’s no requirement for TM59 or TM52 assessments to be submitted with planning applications.

Part O compliance still sits with Building Control as a statutory requirement. Your overheating assessment, whether using the simplified method or full dynamic simulation, remains part of the Building Regs approval process, not planning.

For now, Manchester projects won’t face the dual-stage overheating scrutiny that London developers deal with. Whether that changes in future revisions remains to be seen.

Implementation Timeframes

The Manchester Local Plan is currently at Regulation 18 stage, which is the first full draft out for public consultation. There’s a way to go before it becomes policy:

The Future Homes Standard is due towards the end of this year with a 12-month transitional period. So both hit around the same time. FHS becoming mandatory just as Manchester’s Local Plan gets adopted.

For developers with Manchester projects in the pipeline, this means planning applications submitted from mid-2027 onwards will likely need to satisfy both regimes: FHS via the Home Energy Model for Building Control, and MNZCBS via PHPP or TM54 for planning.

The Reg 19 consultation in summer 2026 is the last real opportunity to influence the final wording. If you have concerns about thresholds, viability definitions, or assessment requirements, that’s the time to submit comments.

We’ll be watching the Reg 19 consultation and will update this article as the policy develops.