Despite research by the UK Green Building Council (Nov 2021) showing that embodied carbon emissions due to the construction process, maintenance and demolition of buildings, created 40 to 50 million tonnes of CO2 annually – more than aviation and shipping combined, the UK government has failed to regulate the embodied
As part of the Government’s plan to cut carbon emissions and hit its net zero climate targets, it has produced a new mandatory Building Regulation that sets out a new requirement to install electric vehicle (EV) charging points or cable routes to new or existing buildings that is due for
Despite research by the UK Green Building Council (Nov 2021) showing that embodied carbon emissions due to the construction process, maintenance and demolition of buildings, created 40 to 50 million tonnes of CO2 annually – more than aviation and shipping combined, the UK government has failed to regulate the embodied carbon cost of construction whilst focusing solely on operational emissions. As a result, experts in the field of decarbonisation have worked together to develop a proposal for amendments to the Building Regulations that could be used to mandate the reporting and limiting of carbon emissions. Head of Sustainability at Whitecode, Ellen Huelin, takes a look at the proposed Part Z amendment to the Building Regulations and the concept of embodied carbon regulation. She argues that without such regulation the UK could easily fail to meet its ambitious carbon emissions targets. There has been a great deal of focus trained on the energy efficiency of properties being built and operational emissions, but not enough attention has been paid to the sustainable aspect of the construction process. I agree with the authors of the proposed amendments to The Building Regulations 2010 that there is the need for legislation to be introduced that would ensure that embodied carbon is assessed on all projects as part of a comprehensive whole-life carbon assessment. The House of Commons’ Environmental Audit Committee agree. In its report in May 2022 entitled Building to net Zero: costing carbon in construction, it states that the single most significant policy the government could introduce is a mandatory requirement to undertake a whole-life carbon assessment for buildings and that this requirement should be set within building regulations and the planning system. It says the government should then develop progressively ratcheting carbon targets for buildings, with a clear timeline for introducing this in place by the end of 2022. This is the biggest indication yet that the government is beginning to listen to our industry which has been actively supporting the concept behind a new Part Z and recognising that, as a result of a lack of policy, no real progress has been made in reducing embodied carbon emissions within the built environment. Our sustainability team at Whitecode has a great deal of experience carrying out whole life-cycle carbon (WLC) emission assessments, that consider operational as well as embodied carbon emissions together over a project’s expected life cycle, because the London Plan (policy SI 2) sets out a requirement for development proposals to calculate and reduce WLC emissions as part of a WLC assessment. London has an ambitious target to become zero-carbon by 2050, but even the London Plan has no specific embodied carbon targets, only ones around reducing carbon in operation. Outside of London it seems that only the most forward-thinking developers or those where sustainability is their Unique Selling Point (USP) are carrying out voluntary whole-life carbon assessments. Policy change will be the quickest route to transform the industry so that we can match countries including the Netherlands, France and Sweden who already regulate embodied carbon emissions. It is frustrating that we are lagging behind others when we have an industry that is calling for it! Any new policy needs to be progressive otherwise the industry will not achieve substantive change. The government’s Future Homes and Buildings Standard will ensure that all future homes will be net zero ready from 2025, if new regulations around embodied carbon emissions don’t come into play soon, this will be a standard that will be difficult to meet. We also need regulation and quickly, around the use of sustainable construction materials to ensure that as an industry we are working towards net-zero. To do this I believe the government needs to incentivise their use and their development. We need to consider the circular economy. We know that we shouldn’t be putting things into landfill and that we should be looking to recycle where possible, but we don’t want to just be able to recycle; we need to be able to re-use construction materials again and again. We need to look at how functional and adaptable they are and ensure they are designed for assembly so they can be remodelled and repurposed. We can no longer just stick materials together if we want to work towards a whole life-cycle approach. Industry standardisation will support moves to regulate embodied carbon. Notes on the proposed Part Z say that a cross-industry team is developing a free-to-use Built Environment Carbon Database (BECD) that will be launched this year, the idea being that it minimises the cost and complexity of the process of measuring embodied carbon. The BECD will also include a product database. The standardisation and bringing together of information is vital to allow new regulations to be easily implemented. The government needs to adopt this approach by standardising methodology, creating reporting frameworks and setting minimum targets for the construction sector. Industry support for regulation is clear, with major developers and industry bodies stepping forward to support the concept of Part Z. I am also seeing a change of mindset coming from within the sector around environmental, social and corporate governance (ESG). Recently I have been asked by a number of clients for advice around ESG and one client has asked me to join their sustainability steering group to help them with the mechanisms of placing sustainability intrinsically within their business. These are positive developments that demonstrate a real appetite by companies to accelerate their reduction in carbon emissions. The government needs to recognise that the construction industry is ready and willing for change. The time is now. There has been a great deal of focus trained on the energy efficiency of properties being built and operational emissions, but not enough attention has been paid to the sustainable aspect of the construction process. I agree with the authors of the proposed amendments to The Building Regulations 2010 that there is the need for legislation to be introduced that would ensure that embodied carbon is assessed on all projects
As part of the Government’s plan to cut carbon emissions and hit its net zero climate targets, it has produced a new mandatory Building Regulation that sets out a new requirement to install electric vehicle (EV) charging points or cable routes to new or existing buildings that is due for implementation in June this year. Approved Document S: Infrastructure for the charging of electric vehicles, applies to new residential and non-residential buildings; buildings undergoing a material change of use to dwellings; residential and non-residential buildings undergoing major renovation; and mixed-use buildings that are either new, or undergoing major renovation. The approved document does not apply to work subject to a building notice, full plans application or initial notice submitted before 15 June 2022, provided the work is started on site before 15 June 2023. The new regulations include specific criteria for each type of building that a developer needs to consider on a new or existing site, as Jamie Mitchell, Associate Electrical Engineer at Whitecode Consulting, explains: “A new housing scheme that requires 100 new car chargers can result in large infrastructure upgrade costs if the existing network is unable to deliver the required power. The new regulations include an average connection cost* cap of £3600 (excluding VAT) per electric charge point. “If the developer can prove that the connection costs exceed £3600 per electric charge point, they will only be required to install the maximum number of charge points until this cost is reached. The developer is then required to install cable routes only** which can be accessed in the future when the infrastructure is upgraded.” To show that the connection cost is greater than £3600 at least two formal quotes must be given to the building control body during the notice/plans stage of a project. At least one quote should be from a distribution network operator. The quote must clearly show the maximum number of EV charge points that can be installed before the extra grid connections costs exceed £3600 per charge point per dwelling. Whitecode Consulting offers a full utility service which includes applications to energy providers. As technical engineers with a team of expert statisticians on hand that are experienced in negotiating with energy suppliers and providing the required technical guidance if a load is going to exceed its cap. As a specialist consultancy, Whitecode provides its clients with three quotations for every project, so it is already exceeding the standards asked for by the regulators in this instance. The engineers at Whitecode have also developed schemes with Dynamic Load Management Systems that can measure the real time power usage of EV chargers on site and can use the capacity of other loads on an installation when they are not in use. This allows for the total capacity on a site to be maximised to provide EV chargers with the total amount of power possible without compromising power quality throughout the site. These will no doubt become more widely implemented as more large-scale car charger installations are required in the future. With the Government planning on banning the sale of new petrol and diesel cars from 2030 there is a real possibility that there will not be enough charger points to meet demand. If the regulations do not go far enough to entice the construction and utilities industries to upgrade infrastructure and provide EV charging points, the move to electric could stall altogether. In a mixed-use development the problem could be exacerbated if service vehicles that may need charging more regularly are competing with residents for access to chargers. Figures published just last month (January 2022) by the Society of Motor Manufacturers and Traders (SMMT), showed that in 2021 plug-in vehicles accounted for a record one in six registrations, while battery electric cars alone rose to one-in-nine, with more registered last year than 2016-2020 combined. The ratio of vehicle charge points to electric vehicles needs to also grow to match this trend. It comes as no surprise that Shell has opened its first electric vehicle charging hub in Fulham, London. It is the first time the company has converted an existing fuel station into one catering solely for electric vehicles. These charging stations will become more common in the future if people are unable to charge their vehicles at home. The new regulation also differentiates between covered and uncovered car parks. There is not as much provision required for covered car parks. Mitchell believes that this is down to the costs associated with upgrading the infrastructure in the future in covered car parks compared to open car parks where the process would be simpler. For new residential buildings, if all car parking spaces sit within a covered section (this excludes garages and car ports), cable routes for chargers must be installed in all spaces if there are 10 or more spaces, or installed in the total amount of spaces per dwelling if there are less than 10 spaces, or all spaces if there are fewer spaces than dwellings. In new buildings other than residential or mixed-use buildings where all parking spaces are within a covered car park, the requirement to install an electric vehicle charge point does not apply. However, cable routes must still be provided for a minimum of one in five parking spaces. “We have worked on a number of large developments over the last few years that have underground basement car parks with a significant amount of car chargers. It’s clear this section of the regulations does not specifically cater to this type of development. This could result in an increased demand for housing with EV chargers in town and city centres.” Mitchell reasons. The Prime Minister Boris Johnson, when announcing the new laws, said the force driving change would not be government or business, but young people who can see the consequences of climate change and will demand better. Mitchell doesn’t believe it is that simple. He said: “Although this new regulation is a significant improvement on the allocation of EV chargers,
