UK100 has submitted a response to the proposed Air Source Heat Pumps Professional Advice Note, which sets out a more proportionate approach to noise assessment for installations requiring planning permission. The submission considers how the guidance can reduce unnecessary cost and complexity, support consistent decision-making, and enable the wider rollout of heat pumps.

It outlines key priorities for the proposed reforms:

Maintaining a proportionate, tiered assessment framework: The proposed three-level approach is broadly supported, as it recognises that not all installations present the same level of risk. However, clearer guidance is needed on how cases move between levels to ensure the framework is applied consistently and transparently.

Avoiding unnecessary cost and complexity for households: Planning and assessment routes should prioritise low-cost, accessible pathways wherever possible. Many installations narrowly fall outside simplified thresholds, and should not be pushed into complex and expensive assessment processes where impacts are likely to be minimal.

Reserving complex assessments for genuinely sensitive cases: Detailed methodologies such as BS 4142 should be used only in exceptional circumstances where there is a clear risk of adverse impact. This ensures that the planning system remains proportionate and avoids unnecessary delays.

Improving consistency across local authorities: Clearer national guidance, shared tools, and standardised approaches are needed to reduce variation in how planning and Environmental Health teams assess applications. This will provide greater certainty for applicants and support faster decision-making.

Supporting flexible and context-sensitive approaches: Introducing options such as split day/night limits or thresholds based on background noise levels could provide more realistic and proportionate assessments, particularly in urban areas where ambient noise is already higher.

Addressing cumulative impacts without creating barriers: While cumulative noise should be considered in certain contexts, evidence suggests that multiple heat pumps are unlikely to create significant impacts in typical residential settings. Evidence suggests that complaints relating to heat pump noise are currently very low, and policy should reflect this in maintaining a proportionate approach. Guidance should reflect this to avoid unnecessary escalation.

Ensuring planning conditions remain proportionate: Planning conditions should be used sparingly, be clearly justified, and not substitute for wider quality assurance frameworks. Clear guidance is needed on when conditions are appropriate to avoid inconsistent application.

Supporting a coordinated awareness campaign: Alongside technical guidance, a clear national communications campaign is needed to build public understanding and confidence in heat pump deployment, address concerns such as noise, and support informed household decision-making.

The submission also emphasised the importance of aligning planning guidance with wider heat decarbonisation policy, ensuring that regulatory frameworks support the scale and pace of heat pump deployment required to meet climate targets.

Overall, UK100 called for continued collaboration with Government and professional bodies to ensure that noise assessment guidance is clear, proportionate, and enables the rapid and widespread adoption of low-carbon heating.

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