British Ceramic Confederation SBE0064
Written evidence submitted by the British Ceramic Confederation
About the British Ceramic Confederation
As a trade association, BCC represents the collective interests of UK ceramic manufacturers. We have around 90 member companies (75% of which are SMEs) that operate from 150 sites across the country.
Our sector is extremely diverse containing both foundation industries and advanced manufacturing / materials and comprises: producers of heavy clay construction products (such as bricks, blocks, roof tiles and drainage pipes); sanitaryware; wall tiles; tableware; giftware; refractories (that are vital in all high-temperature process industries); advanced ceramics (for numerous electronic, medical, aerospace, environmental, military and structural applications) as well as suppliers of raw materials to the sector.
The sector is energy-intensive (but not energy-inefficient), with energy costs and taxes making up to 30-35% of total production costs. By virtue of regulatory obligations such as the EU Emissions Trading Scheme (now UK ETS) and the importance of energy to their overall costs, our members focus is already to maximise the energy efficiency of their operations. The sector has already taken extensive action to decarbonise and has some of the world’s most efficient ceramic manufacturing operations.
The ceramic sector (and energy intensive industries in general) are central to supporting the transition to a competitive low-carbon and resource-efficient economy, including the production of highly durable products with low lifecycle carbon footprints.
Achieving ‘net zero’ greenhouse gas emissions by 2050 will be very challenging for the ceramics industry and its supply chain. The UK ceramic industry is a solution provider for the net-zero economy and is committed to working in partnership with Government and others to decarbonise in line with net-zero. To build on considerable progress made in tackling manufacturing emissions so far, companies are working together under the auspices of a new sector initiative: “British Ceramics: Towards Net Zero”.
More information is available at: www.ceramfed.co.uk
This is a response to the Select Committee’s call for evidence on the sustainability of the built environment. Our evidence responds to each of the Committee’s questions in turn:
Q1 To what extent have the Climate Change Committee’s recommendations on decarbonising the structural fabric of new homes been met? No response.
Q2 How can materials be employed to reduce the carbon impact of new buildings, including efficient heating and cooling, and which materials are most effective at reducing embodied carbon?
- A building must be fit for purpose, meeting a range of requirements including safety, structural performance, durability and contextual needs. Therefore, carbon assessment should be made at the building level as part of the overall design process.
- Construction products can be utilised to reduce the whole life carbon impact of new buildings. Key to this is recognition that buildings are systems and good design is critical to minimising carbon impact throughout their lifecycle (from the extraction of materials, manufacture and assembly of products, to in use, maintenance and end of life). Therefore, careful selection and evaluation of products at the building level is needed to assess the carbon impact over the whole lifecycle of a building.
- The ceramic sector is energy-intensive (but not energy-inefficient) and central to supporting the transition to a competitive low-carbon and resource-efficient economy, including the production of highly durable construction products with low lifecycle carbon footprints. The sector has already taken extensive action to decarbonise and has some of the world’s most efficient ceramic manufacturing operations. Over the last 5 years, the sector has invested £250 million; examples of recent and ongoing investments include Forterra (Desford) and Ibstock Brick (Eclipse and Atlas Works) (i).
- When assessing which products will give the optimum results, there are a range of factors that need to be taken into account to ensure a fair evaluation takes place. Our response to question 5 (What methods account for embodied carbon in buildings and how can this be consistently monitored and applied across the sector?) sets out some of the concerns associated with accounting for embodied carbon, but these aside, the following points also highlight issues with the assessment of the carbon impact of new buildings and why caution is needed:
- Organisations / policy-makers / individuals evaluating whole lifecycle carbon impact need to understand how products have been assessed and carbon values calculated, including the scope, the generic databases used (e.g. Ecoinvent or Gabi) and any assumptions made. For example, the brick sector in the UK has produced a Generic Brick Environmental Product Declaration (EPD)(ii) that uses the latest standard version EN 15804:2012+A2:2019, which mandates that modules A-D are covered and includes additional indicators compared to the previous version. This enables a whole lifecycle carbon impact comparison to be made - from material extraction to end of life, but some EPDs only cover ‘cradle to gate’ impacts.
- The building design, materials selected and its construction will have an impact on operational carbon; therefore, assessments should take place at the building level and products selected that deliver a low carbon impact for the whole service life of the building:
- Ceramic construction products are durable and have long service lives (brick, 150 years, roof tiles, in excess of 60 years and clay pipes, 100 years).(iii)
- Products will have different repair and maintenance requirements (and associated emissions) during their lifecycles.
- The source of construction products (indigenous or imported) will impact carbon emissions from transport.
- Building design and the products used will impact the need for heating and cooling during the ‘in use’ phase. Ceramic bricks and roof tiles have a high thermal mass which is a material's capacity to absorb, store and release heat. This means that there can be benefits of solar gain, and peak temperatures can be reduced, limiting the need for additional heating and cooling. (Examples include the Wienerberger E4 house(iv) and Passivhaus(v)).
- In summary, when considering which products can reduce embodied carbon, it is important to understand that a product with low embodied carbon will not necessarily lead to a reduction in carbon emissions over the whole lifecycle of the building. Products need to be assessed in the context in which they will be used, including aspects such as the expected service life of the building, and impact on operational carbon.
Q3 What role can nature-based materials play in achieving the Government’s net zero ambition?
- All construction products will have an environmental impact regardless of origin. This includes nature-based materials which are grown or farmed, with a range of potential inputs including nutrients, herbicides and pesticides, and then subject to processing. Also to be taken into consideration is the impact that the increase in the use of such materials may have on the environment as a whole, for example, the reduction in biodiversity through the cultivation of plantations. Clay is a natural material that is used to manufacture a range of construction products in the UK that are durable, have long service lives and can help to reduce operational carbon when buildings are in use. Clay extraction sites in the UK are carefully managed and restored over many decades, providing a range of environmental, biodiversity and amenity benefits. This highlights that for the impact of different products to be understood, a whole life cycle assessment (which includes a range of environmental factors) needs to be carried out.
- Nature-based materials may facilitate the achievement of the Government’s net zero ambition for construction, provided they are used appropriately with the whole lifecycle impact of the building taken into account.
Q4 What role can the planning system, permitted development and building regulations play in delivering a sustainable built environment? How can these policies incentivise developers to use low carbon materials and sustainable design?
- The National Planning Policy Framework has sustainable development at its core, stating ‘The purpose of the planning system is to contribute to the achievement of sustainable development’, and going on to say ‘Achieving sustainable development means that the planning system has three overarching objectives, [economic, social and environmental] which are interdependent and need to be pursued in mutually supportive ways (so that opportunities can be taken to secure net gains across each of the different objectives).’
- Planning policy can be used to help deliver a sustainable built environment and there should continue to be a flexible approach so that the different aspects of sustainable development can be evaluated and planned for as part of the local planning process. There are a range of environmental aspects that need to be taken into account, of which embodied carbon is just one, therefore any moves to change the planning system must allow for balanced decision making (acknowledging that climate change is a key priority but there are other aspects that need to be considered and that these may vary depending on the local context).
- The planning system should not be prescriptive about solutions, (as different contexts will have varying needs), but clear about policy aims and ultimate performance requirements will be beneficial in delivering a sustainable built environment.
Currently there is insufficient data to make detailed, evidenced based analyses of embodied carbon at the building level and there is the danger that an overly-prescriptive approach will not actually lead to the best outcome for the environment as a whole or for those that will be living or working there. It is our view that the planning system and building regulations should reinforce the principles of circular design, with carbon impact an important aspect to be balanced with other sustainability and circular economy objectives:
- Design for longevity - buildings should be made from durable components and resilient to climate change.
- Design for service - buildings should be low maintenance, non-toxic and energy efficient, with high comfort for users.
- Design for reuse and refurbishment – buildings should be upgradable, adaptable and convertible.
- Design for material recovery – building components should be traceable and wherever possible, reusable and recyclable.
- Building-level carbon disclosure or carbon cap standards could be governed by building regulations or planning permissions but there are a number of issues associated with accounting for embodied carbon and the use of such information that must be taken into account when considering the implementation of such an approach.
Q5 What methods account for embodied carbon in buildings and how can this be consistently monitored and applied across the sector?
- There are a range of different guidance, tools and standards, which can be used to account for embodied carbon in the built environment(vi), which make it challenging to compare this aspect of performance fairly across different construction products or projects.
- The Committee on Climate Change identifies embodied emissions as those that caused by the extraction, manufacture and assembly of materials plus maintenance and end-of-life disposal(vii) but this definition does not include transport or ‘in use’ (operational) emissions.
- For construction product manufacturers, the most well-established assessment method is the use of Environmental Product Declarations (EPD), which cover a range of environmental lifecycle impacts, including carbon emissions (BS EN 15804:2012+A2:2019 Sustainability of construction works. Environmental product declarations, set out the Product Category Rules (PCR)). Although EPDs are used extensively and the approach has developed over a number of years, there are a number of limitations that users need to be aware of:
- EPDs are voluntary and although over 10,000 verified EPD to EN 15804(vii) have been calculated, the quality and scope of data is variable. Also, the quality and age of environmental information in EPD reference databases and the assumptions made by programme operators when calculating EPDs is not consistent. EPDs can hold third party verification but these issues are still apparent.
- EPDs can be calculated based on different scopes and currently most only measure the ‘cradle to factory gate’ emissions (rather than whole lifecycle). This is an issue as it means some EPDs do not provide information on the construction, use or end of life phases, all of which can have a significant impact.
- EPDs should only be used to inform product comparisons and selection when the same PCR have been used and all the relevant life cycle stages have been included, however, users often look at the headline result without understanding the scope or aspects such as the service life of the product.
- If the carbon impact of buildings is to be calculated and results used to inform decision-making, there must be a clear methodology, the scope of assessments must be comparable, and users must understand that:
- Embodied carbon and in-use carbon emissions from the operation of the building, as well as the carbon associated with transportation and at end of life, together make up the whole lifecycle carbon assessment of the building.
- A low-carbon component will not necessarily lead to a low-carbon, high quality building over its lifetime. There may be other unintended implications for levels of operational carbon due to poor durability, resilience and adaptability, and repair and maintenance and heating and cooling requirements.
- BS EN 15978:2011, a standard to assess the environmental performance of a building, may be appropriate as a standard methodology. This standard is currently under revision.
- Reducing embodied carbon in construction products is a key part of reducing carbon emissions associated with construction, but when undertaking any analysis it is critical that a building level assessment takes place so that other aspects of product performance and the building context in which they are used are also part of the evaluation.
Q6 Should the embodied carbon impact of alternative building materials take into account the carbon cost of manufacture and delivery to site, enabling customers to assess the relative impact of imported versus domestically sourced materials?
- Yes, reducing carbon emissions is a global challenge; therefore, it is crucial that transport emissions be taken into account if a fair assessment of the impact of different construction products is to be made. The ultimate goal is to reduce emissions; it does not make sense to overlook potentially significant impacts from analysis, and give misleading results.
- Making embodied carbon available for both imported and domestic products would help buyers make informed, environmentally sound decisions.
- As set out in the Institute of Structural Engineers Climate Emergency group – How to calculate embodied carbon(vii), embodied carbon analysis must have a minimum scope of analysing the building elements and at least the life cycle stages of; manufacture, transport to site, construction, maintenance, and replacement.
Q7 How well is green infrastructure being incorporated into building design and developments to achieve climate resilience and other benefits? No response.
Q8 How should we take into account the use of materials to minimise carbon footprint, such as use of water harvesting from the roof, grey water circulation, separate foul and surface water drainage systems, porous surfaces for hardstanding, energy generation systems such as solar panels?
- It makes sense to promote and encourage the use of measures that will help minimise the carbon impact of developments throughout their lifetime by reducing operational carbon. Government policy should encourage the implementation of solutions such as rainwater harvesting, SuDS and energy generation systems to support a reduction in operational carbon, especially as these will also have wider environmental benefits and support climate resilience.
Q9 How should re-use and refurbishment of buildings be balanced with new developments?
- With regards to housing, a widely quoted figure is that 80% of the 2050 housing stock is already built(ix) therefore it is imperative that steps are taken to reduce the carbon emissions of existing housing stock, as well as improving the performance of new build properties. When deciding whether reuse and refurbishment or new build is the best option, each case should be assessed on its own merits, considering a range of factors including embodied carbon, raw material consumption, waste generation, biodiversity, and cost.
Q10 What can the Government do to incentivise more repair, maintenance and retrofit of existing buildings?
- Government policy and funding should be used to further encourage the repair, maintenance and retrofit of existing buildings, focusing on those building where the need is greatest. However, after changes to and the closure of previous schemes such as the Green Homes Grants, industry and homeowners are now wary and efforts will need to be made to build confidence again.
- Examples of recent investment in brick manufacturing plants: Forterra Desford (https://www.forterra.co.uk/about-us/desford/), Ibstock Eclipse (https://www.ibstockbrick.co.uk/news/brokenshire-opens-ibstock-brick-new-eclipse-factory-which-will-help-build-up-to-15000-new-homes-a-year/) and Ibstock Atlas Works (https://www.ibstockplc.co.uk/newsroom_textonly/year/2021/ibstock-plc-confirms-investment-pathfinder-project-achieve-worlds-first).
- Generic Brick Environmental Product Declaration (https://www.greenbooklive.com/search/scheme.jsp?id=283).
- Service lives of clay bricks, roof tiles and clay pipes:
- Clay brick (Brick Development Association - Clay Brick: End of Lifecycle https://www.brick.org.uk/admin/resources/clay-brickwork-end-of-lifecycle-rev-b.pdf).
- Roof tiles (BRE - https://www.bregroup.com/insights/ageing-roof-tiles/).
- Clay pipes (Clay Pipe Development Association - https://www.cpda.co.uk/pipe-characteristics/durability/).
- Wienerberger Plc E4 house (https://www.wienerberger-building-solutions.com/Expertise/Wienerberger-e4-house.html).
- Passivhaus (https://www.passivhaustrust.org.uk/).
- Examples of guidance and tools to calculate embodied carbon:
- The Institution of Structural Engineers – How to Calculate Embodied Carbon (https://www.istructe.org/IStructE/media/Public/Resources/istructe-how-to-calculate-embodied-carbon.pdf).
- UK Green Building Council – Practical How to Guide: Measuring Embodied Carbon on a Project (https://www.ukgbc.org/sites/default/files/UK-GBC%20Embodied%20Carbon%20guide.pdf).
- RICS Whole life carbon assessment for the built environment (https://www.rics.org/globalassets/rics-website/media/news/whole-life-carbon-assessment-for-the--built-environment-november-2017.pdf).
- EN 15978 Sustainability of construction works. Assessment of environmental performance of buildings. Calculation method
- BRE – IMPACT specification and database and associated tools: https://www.bregroup.com/impact/.
- Carbon footprint calculators for construction: https://circularecology.com/carbon-footprint-calculators-for-construction.html.
- More than 10,000 EPD verified to EN15804 have been calculated: https://constructionlca.co.uk/2021/01/17/more-than-10000-en-15804-epd-at-the-start-of-2021/
- UK Housing: Fit for the Future? The Committee on Climate Change (2019). https://www.theccc.org.uk/publication/uk-housing-fit-for-the-future/
- UK Green Building Council: https://www.ukgbc.org/climate-change/#:~:text=Newly%20constructed%20buildings%20are%20more,is%20decarbonising%20our%20existing%20stock