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​Why we need embodied carbon regulation now

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Joe Giddings and Seb Laan Lomas explain why the UK government urgently needs to catch up with leading thinkers at home and abroad 

In Finland an ambitious architect turned policy-maker named Matti Kuittinen is working for the Ministry of Environment developing a regulation that will transform the way that buildings are built. It will introduce mandatory targets, or carbon budgets, for all new buildings.

The budgets will be set by building type and accurate assessment will be made possible by the Finnish government establishing a national database of Environmental Product Declarations (EPDs), the documents that describe environmental data for materials and products.

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This pioneering policy will be introduced by the middle of the decade and is being developed as part of Finland’s aim to be carbon neutral by 2025 and carbon negative by the 2040s. This latter goal clearly permeates throughout government culture, as Matti described the ambition to make buildings ‘not just less bad, but more good too’.

Alongside colleagues from the Embodied Carbon group at ACAN, we spoke to Matti in June and peppered him with questions on how this policy will be implemented. There are currently no such regulations in place in Finland but, instead of introducing a transitionary period for industry to adapt, they are going straight for strict limit values.

Matti simply refers to the urgency of the situation: ‘Ambitious targets need to be set from the beginning in order to reach our climate goals.’ He frankly admits they are ‘jumping in at the deep end’.

If you find yourself thinking that Finland’s modest population and Nordic sensibility allows this agility, then turn to consider France. Two steps ahead, the country has already been trialling such a policy on a voluntary basis since 2016, using this four-year period to build up a database of project data. The plan, called ‘E+C-‘ (Energy Positive and Carbon Reduction), is about to enter phase two, which will see the measurement of whole-life carbon become mandatory for new buildings.

We stand to learn a lot from these French and Finnish initiatives. The ambition, clarity and leadership is noteworthy during a period in which we have often lacked good news. Atmospheric carbon continues to rise despite a significant but momentary dip in emissions due to coronavirus lockdown measures curtailing energy use worldwide. Our news feeds are now occupied with a regular stream of alarming weather events.

But, while the climate penny has finally dropped in the UK construction industry, significant barriers remain to real progress being made on the scale seen on the Continent. Thanks to decades of hard work, operational carbon in new buildings is falling.

But, as the industry turns to consider the other side of the coin, we know we don’t have anywhere near as long to deliberate in reducing embodied carbon. We need to do everything we can, as fast as we can, to stand a chance of limiting warming to 2 degrees and meeting the UK’s legally binding emissions targets.

Picking through various reports from the past few years, we can see this kind of policy has been floated before, here in the UK. It was explored by the government’s own climate advisers, the Committee on Climate Change. They commissioned a report by AECOM in 2019 looking at ‘options for bringing embodied carbon into the building standards framework’. It came to the somewhat obvious conclusion that ‘mandatory targets are likely to be more effective’ than the kinds of voluntary codes that currently exist in this country.

The Building Regulations should be developed to eventually include whole-life carbon emissions

Even further back, in 2014, an ‘Industry Task Force’ comprising large engineering firms such as Arup and Atkins and leading sustainability consultants including Sturgis Carbon Profiling recommended routes to embodied carbon regulation.

It stated unequivocally: ‘The Building Regulations should be developed to eventually include whole-life carbon emissions.’ To date, the findings and recommendations from both of these reports are yet to be enacted. Despite the knowledge that this policy will take years to develop, the government hasn’t even started assembling the team.

But these are ideas whose time has come. Within the void left by this frustrating lack of government-led action, an incredible array of voluntary working groups have been established to grapple with the enigmatic beast that is embodied carbon.

ACAN’s group is reviewing global legislation to build the case for UK regulation. LETI’s group, led by Helen Hough, Kat Scott, Raheela Khan Fitzgerald and others, is defining targets and strategising how to get the construction industry on board. An RIBA group is identifying benchmarks. The Whole Life Carbon Network, led by Simon Sturgis and others, has created a forum for industry leading experts to define best practice. The US-based Carbon Leadership Forum has started a UK chapter for transatlantic collaboration on the topic.

The energy and the drive exists, but what we need now is clear unified leadership from our institutions and from government. The RIBA can use its voice to call on government to set the wheels in motion; establishing a national EPD database, settling on an agreed methodology and agreeing reporting requirements so that every new building will contribute to a shared data set. These actions will enable the drafting of new parts to the building regulations and national planning policy.

Working together with architects and engineers like this, the government has a chance to do something truly revolutionary. The industry is waiting for the call.

Joe Giddings and Seb Laan Lomas are co-ordinators for ACAN. Joe is an architect at Rock Townsend and Sebastian an architect at Hopkins. Both are running for RIBA Council in the current round of elections 

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Readers' comments (1)

  • We are so far off being educated enough on this issue that noone else has felt able to comment yet...

    its not some new science, we have just failed to teach and implement it for the last 30 years. This generation doesnt haev the luxury of pushing it onto the next though, we have to get up to speed fast!

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