The first part of this series of posts, “Net zero”, church heating, and the consistory courts – I, (24 May 2021), reviewed twelve judicial considerations of replacement heating schemes, most of which had been handed down post-February 2020, the date on which General Synod unexpectedly agreed to the “net zero by 2030” target for the Church of England’s greenhouse gas emissions. The judgment Re St. Thomas & St. Luke Dudley  ECC Wor 2, delivered on 5 May and circulated on 29 May 2021, was considered in the second part, “Net zero”, church heating, and the consistory courts – II. Here the Chancellor raised the fundamental issue how the consistory courts should approach cases involving the Church of England’s “net zero” target. These two contrasting approaches are discussed below, and areas of commonality explored. For completeness, a further two recent judgments are included in the Postscript.