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Sustainable Places for Everyone: What the new net zero guidance means for Greater Manchester developments

Following the Greater Manchester Combined Authority’s (GMCA) publication of net zero guidance to support Places for Everyone (PfE), Head of Sustainability & ESG, Fiona Lomas-Holt provides her insights on the key points on energy and carbon, impacts on planning applications and submission requirements, plus potential implications for developments across Greater Manchester.

What GMCA has published

In March 2025, the GMCA released four documents to support the implementation of PfE:

• Design Guidance for Net Zero - guidance for applicants on how to design to achieve net zero carbon buildings.
• Low Carbon Heat - guidance for applicants on how to deliver heating systems which are low carbon, cost effective and affordable.
• Submission Guidance for Places for Everyone policies JP-S2 and JP-S3.
• Energy and Low Carbon Proforma to demonstrate compliance.

This sets clearer expectations on how Greater Manchester schemes will manage energy demand and carbon under Places for Everyone. Below, we take a look at what this means in practice, drawing on the first few months of implementation. For teams that would like a more detailed overview, you can contact me for a CPD session covering this in more depth.

New KPIs and targets 

The Design Guidance for Net Zero includes several new KPIs and metrics which have not been raised previously within policy or part of a consultation process. Whilst many KPIs align with emerging legislation such as the Future Home Standard / Future Building Standard, others go further and will benefit from early feasibility and viability testing to support applications.

The following KPIs / metrics are proposed for major residential:

• Space heating demand ≤20kWh/m².yr for houses and ≤15kWh/m².yr for flats
• Energy use intensity of ≤35kWh/m².yr (this metric is listed as a target only for residential, however, it is a requirement for social housing, which are expected to meet Truly Affordable Net Zero (TANZ) standard)
• Fossil fuel free
• Solar PV installed to the equivalent of at least 40% floor space
• Building regulations Part O (overheating) compliant without cooling
• Upfront carbon target of ≤500kgCO2/m² for houses and ≤600kgCO2/m² for flats

Part O, fossil fuel free and Solar PV targets either already sit within, or are expected to align with,  national legislation. As the EUI and upfront carbon targets are not stated in PfE, the weight they carry is unclear tested through applications. By contrast, the space heating demand is more stringent than emerging legislation and is written into PfE – it will therefore carry weight in applications.

The following KPIs / metrics are proposed for major non-residential:

• Space heating demand ≤15kWh/m².yr
• BREEAM Excellent from adoption and Outstanding from 2028 for energy (credit issue Ene 01)
• Fossil fuel free
• Solar PV installed (no specific area given)
• Minimise overheating
• No specific upfront carbon target

The targets above for non-residential buildings are close to standard practice. However, this will vary between building types, and the space heating in particular could be challenging for buildings with high heating loads (e.g. hotels and purpose built student accommodation), and therefore early checks are advisable.

Meeting the BREEAM Ene 01 requirements appears achievable at present, however, with the recently released BREEAM ‘Version 7’ remaining untested and increased in stringency from Version 6, it would be wise to plan for a step-up in complexity from 2028 when the policy aligns with ‘Outstanding’ standards.

Low Carbon Heat

The Low Carbon Heat guidance document provides applicants with further information on how to deliver low carbon heating systems in line with policies JP-S2 and JP-S3. It confirms that gas-fired heating systems are not compatible with achieving net zero carbon buildings and recommends the use of all-electric heating systems such as heat pumps.

A ‘low carbon heat appraisal’ is recommended for all applications which should set out performance against metrics such as carbon content of heat, local pollution, energy costs for heating and hot water, viability, and operating costs.

Submission Guidance

The Submission Guidance confirms the following is required for each application:

• Energy and Carbon Statement
• Energy and Carbon Proforma

Level of detail is proportionate to stage – outline can be completed based on high-level targets, whereas detailed or reserved matters requires demonstration of performance against all KPIs. Forming an early view is valuable to support flexibility in application.

To support these documents and report against the KPIs, additional supplementary reports will be required including:

• Whole Life Carbon Assessment (WLCA)
• Energy Modelling
• Overheating Study
• Low Carbon Heat Appraisal

Advice can be provided early in the project process on how to best to scope, deliver and programme these studies.

Financial contributions – carbon offsetting

The financial contribution via carbon offsetting to achieve net zero carbon has not been confirmed in PfE or the latest GMCA guidance. The guidance states that “the decision to include offsetting will be determined by each local authority in Greater Manchester, with options for offsetting currently under development”.

As it stands, the scope of the offsetting is subjective and whether this applies to all regulated, unregulated, and construction carbon is yet to be clearly confirmed. If contributions apply to all operational carbon emissions (regulated and unregulated) and construction carbon emissions, then costs could be significant and practicality should be considered. PfE policy states that net zero is expected unless not feasible or viable.

Key considerations for development moving forward

Relating to the new PfE net zero requirements, we see the following as the key considerations to take forward at glance:

• Pre-planning scope – the number of reports required pre-planning has increased to address to the net zero requirements.
• Uncertainty over KPIs – generally the metrics listed within the guidance documents align with forthcoming national standards (Future Home Standard / Future Building Standard), however, the EUI and upfront carbon targets may be particularly challenging for residential buildings and the design guidance’s weight will be tested through applications.
• Space Heating Demand – the space heating demand targets for houses exceed the Future Homes Standard and will require further specification upgrades and implications should be assessed early. 
• Offsetting – there are outstanding areas where further clarity will be defined by local authorities including the scope of emissions covered, how contributions are calculated and at what stage this will be sought.

We welcome Greater Manchester’s ambitions for high quality, sustainable and net zero buildings, and look forward to helping developers and design teams deliver these ambitions.

For advice on how the guidance applies to your scheme, or to arrange a CPD for your team – contact Head of Sustainability & ESG, Fiona Lomas-Holt.

22 August 2025