Regulating Embodied Carbon

UK Architects Climate Action Network (ACAN) Report (February 2021)

ACAN is calling for the urgent introduction of legislation to regulate embodied carbon emissions generated by construction activities in the UK. Current policy and regulation focus solely on operational energy use as distinct from embodied carbon, and there are currently no national planning policy or building regulation requirements to assess, report or reduce embodied carbon emissions.

ACAN believes that only new regulations covering embodied carbon emissions will enable the UK to meet its commitments under the Paris Agreement and reduce its emissions to true net-zero (which must include both operational and embodied carbon emissions) by 2050; now a legal obligation enshrined in the Climate Change Act 2008.

In this report, ACAN asks for clear actions to be urgently adopted for the regulation and thus the dramatic reduction of embodied carbon emissions, with no further delay, including:

The Building Regulations

• Expanding The Building Regulations to include requirements to assess, report and reduce embodied carbon, within a new part: “Part Z: Embodied Carbon Emissions”
• Compliance to be achieved through a “Whole Life-Cycle Carbon Assessment” following the British Standard BS EN 15978
• Limits placed on embodied carbon emissions set by building type
• Regulation 7 to be revised to introduce carbon limits on specific materials

Planning Policy

• Clauses to be introduced to the National Planning Policy Framework with requirements for Whole Life-Cycle Carbon Assessments to be submitted at three stages for all new buildings; as part of pre-application enquiries, full planning submissions, and at practical completion
• As an immediate measure New London Plan Policy SI2 to be adopted by local authorities around the UK

Whole Life-Cycle Carbon Datasets

• Create a freely accessible UK Environmental Product Declaration (EPD) database, or adopt an existing freely accessible database, to ensure consistent and reliable assessments
• Require Environmental Product Declarations to be submitted to the database from construction material suppliers above a certain size, with trade bodies assisting smaller organisations
• Establish a freely accessible database for anonymised Whole Life-Cycle Carbon Assessment data of new buildings, to ensure lessons are widely learnt.

In parallel ACAN has set out a timeline that will enable the UK to meet its commitments to be Net Zero Carbon by 2050 and includes the following milestones:

• 2021: Adopt RICS “Whole Life Carbon Assessment for the Built Environment” as the nationally agreed methodology for measuring embodied carbon emissions; Revise Regulation 7; New London Plan Policy SI2 to be adopted by local authorities around the UK
• 2022: All developments required to assess and report embodied carbon emissions
• 2025: Introduce strict limit values on embodied carbon emissions for all developments
• 2028: First reduction in limit values for all developments
• 2030 – 2040: Continually review and lower the embodied carbon limit values. By 2040 whole life-cycle carbon emissions for all new and refurbished buildings should achieve net-zero.

ACAN believes that embodied carbon emissions will remain the unturned stones of the UK construction industry – with dramatic consequences for the lives of millions – as long as these proposed measures are not adopted.