University of Wolverhampton SBE0071

Written evidence submitted by the University of Wolverhampton


Avoiding Unintended Consequences through Improved Definitions, Better Understanding, and Enhanced Common Processes: A Response from the School of Architecture and Built Environment (SoABE), University of Wolverhampton by Mr Richard Davies MBE, Dr Paul Hampton, Mr Glenn Barrowman, Professor Chaminda Pathirage, Mr Michael Ciotkowski, and Professor Mohammed Arif, 14 May 2021.


Preamble and Recommendations


1. This submission from the University of Wolverhampton is based upon the research underpinning two funded programmes of work, namely Built Environment Climate Change Innovations (BECCI) and Environmental Technologies and Resource Efficiency Support Service (EnTRESS), and the work of two research centres: the Brownfield Research and Innovation Centre (BRIC) and the Construction Futures Research Centre (CFRC).


2. The submission makes a series of recommendations, of relevance to the public policy debate, especially regarding the avoidance of unintended consequences through improved definitions, better understanding of the difficulties regarding embodied carbon, and the requirement for enhanced common processes.







3. There are several assumptions accompanying the public policy discourse more generally that are in danger of obscuring the development of best practice and which need defining at the outset. The first is that ‘local’ manufacture or sourcing does not equal low carbon, equating the brevity of travel with other factors is a false assumption. The second is that ‘carbon-free’ hydrogen is often considered more environmentally friendly, but this omits consideration of embodied carbon. The third point is that ‘nature based’ materials do not necessarily mean low-embodied carbon or low in-use carbon. These distinctions are important because failure to appreciate them would lead to well-intentioned actions having unintended consequences.






Responses to Questions


I - To what extent have the Climate Change Committee’s recommendations on decarbonising the structural fabric of new homes been met?


4. This has been met to a very limited degree, for four reasons:






II - 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?


5. This could be achieved by using materials that have low-embodied carbon, or high levels of sequestered carbon or are highly re-useable, or by constructing buildings with very long lifetimes, i.e. depreciating the amount of embodied carbon over time.[5] This could be improved upon by increasing stakeholder awareness and understanding. For example, the following are positive developments: low maintenance buildings, easily modifiable buildings, MMC/off-site construction, highly re-useable and recyclable materials, and buildings with a very long life.


6. This question can be further addressed by helping all of those involved in construction to know what good looks like, and what the consequences of switching to a lower embodied carbon and/or higher sequestered carbon material might be. There is need for an honest broker entity to provide support, guidance and information with statutory powers, as required.


7. Current regulation and policy prioritises in-use carbon over embodied carbon but needs to change. For example, heat pumps and hydrogen burnt in ‘boilers’ are currently being discussed as the principal space heating approaches for delivering net zero in homes through to 2050. Heat-pumps are complex, and it is likely that they will have a high amount of embodied carbon in their creation, installation and maintenance. This is not visible in the debate. As mentioned at Paragraph 3, above, hydrogen although carbon free ‘in-use’ may have a significant ‘embodied’ carbon depending on how it is produced: for example from steam reformation of natural gas.[6] Alternatively the highly efficient heating technology of far infra-red laminates are a relatively simple technology with relatively low levels of embodied carbon, little need for maintenance and predicted long in-service lifetimes. However because their consumption of electricity is likely to be somewhat higher than a heat-pump they do not feature in current Government thinking about the future of heat in homes.[7]


8. Our experience shows that, for the delivery of low-embodied carbon buildings, there needs to be a requisite training and regulatory infrastructure, including incentivisation and a clear timescale for action. Clear understanding of the process and what it requires is key, as is the need to develop an understanding of what the embodied carbon is of alternative building materials.[8] The development of low/zero embodied carbon materials as a goal for the future also requires strong encouragement.


III - What role can nature-based materials play in achieving the Government’s net zero ambition?


9. The assumption underpinning the question is that ‘nature-based materials are intrinsically low carbon. As framed at Paragraph 3, care needs to be taken, as nature-based does not necessarily mean low embodied carbon, high sequestered carbon or low in-use carbon. The ‘harvesting’, processing, transportation, maintenance, serviceable lifetime and other attributes may result in the nature-based material having more embodied carbon or more in-use carbon than a non-nature-based alternative. Wood is not necessarily good.[9]


10. There is an associated need to approach all materials with a common methodology for calculating embodied carbon including the carbon used in transportation, storage, construction, maintenance, deconstruction, re-use, recycling, and disposal. Only then can we accurately ascertain which nature-based materials are able to play a role in achieving the Government’s net zero ambition.


IV - 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?


11. Before going on to answer the questions, it is important to make the point that, in the current system of regulation, in-use carbon trumps embodied carbon. The troposphere does not care where the climate change gases arise, and neither should we. Our only goal should be to reduce emissions from any and all sources as rapidly and sustainably as possible. There are significant unintended consequences arising from the UK’s territorially based carbon emissions inventory reporting system. For example, French cement and Chinese solar panels are embodied carbon free to the UK under the current territorial accounting framework, but the emissions associated with producing Shropshire oak for a timber framed house, or Cumbrian sheep’s wool insulation for its loft, count towards our emissions targets. By the same token, a low-embodied carbon building in the wrong place is equally problematic. Calculating embodied carbon is complex. Given globalised construction material supply chains, the UK’s construction industry has to rely on embodied carbon declarations from elsewhere – the lack of comprehensive agreed international standards makes this area fraught with challenges. 


12. A clear chain of custody and methods such as embodied energy/carbon tagging and block chain are needed in order to ensure certainty, traceability, and transparency. This mechanism would add value to building regulations and the planning regime. In order to move forward, there needs to be a combination of incentives and regulation. While incentives like stamp duty and VAT may confer costs and benefits to individuals and the market,[10] it is the opinion of the authors of this submission that robust regulation is required, especially given the urgency for action well before 2050.


V - What methods account for embodied carbon in buildings and how can this be consistently applied across the sector?


13. Currently there is very little accounting for embodied carbon in new buildings. There is even less activity in accounting for embodied carbon in existing buildings during maintenance, refurbishment, and modification.


14. As things stand, accounting for the depreciated embodied carbon of existing buildings is not part of the Planning Approval process. For example, the recent expansion of Permitted Development Rights to include the demolition and rebuilding of certain types of existing buildings without consideration of the spent embodied carbon.[11]


15. This inconsistency could be addressed by measures such as internalising the externality of carbon in the cost of a product, which would go some way to incentivising the use of lower embodied carbon building materials.[12] Standardisation could be partially achieved through adherence to structures like the EU Emissions Trading Scheme for elements of the supply chain, for example cement, in order to incentivise lower carbon products. This could be accompanied by making voluntary codes which place a value on embodied carbon in buildings, such as LEED and BREEAM, mandatory.[13]


VI - 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?


16. There is a need to be mindful that much of the way the system functions is counterintuitive. Yes, there needs to be a scheme that objectively reports embodied carbon but local does not necessarily mean low embodied carbon; alternative does not necessarily mean better. As our preamble and responses to other questions also demonstrate, there is the potential to make the situation worse by adopting materials that superficially seem to be low carbon, but which have high embodied carbon. A strong and comprehensive regime would do a great deal to mitigate against these unintended consequences.


VIII - 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, porous surfaces for hardstanding, energy generation systems such as solar panels?


17. Regulations and incentives should encourage greater enforcement regarding adoption and use of project-appropriate technologies and uses of materials that save in-use carbon, or provide a benefit through site climate adaptation but have a carbon cost. Training and capacity building is, as a result, required. This is undoubtedly complex and is a difficult area in which to develop policy without unintended consequences. At the moment, the regulations allow for the construction of a low/zero in-use carbon building through the use of very carbon intensive construction materials. The opposite is not allowed. Over the lifetime of buildings built these ways, the latter example may result in lower overall carbon emissions, but the regulatory environment would preclude it.


IX - How should re-use and refurbishment of buildings be balanced with new developments?


18. 3D scanning technology is one of the enablers that would help to unlock the re-use and refurbishment of buildings, otherwise left unused. This is particularly the case for buildings within brownfield sites. Our work has shown how the use of technology such as laser scanning[14] and drones help put redundant buildings back into use, which otherwise would have been left derelict and unsafe. 3D laser building scans combined with drone imaging, of both internal and external elements, can help with the repurposing of buildings. This enables virtual walk throughs to enhance the visualisation.


19. Research has shown that there is a significant performance gap[15] between design energy performance and actual energy performance in new build. This must be urgently addressed. One of the businesses that BECCI works with, Veritherm (, are developing a validation technology that verifies the actual thermal performance of a building.[16]


X - What can the Government do to incentivise more repair, maintenance and retrofit of existing buildings?’


20. The UK has had struggled to put in place an effective mechanism for incentivising the low carbon refurbishment of homes. The Green Deal & Green Homes Grant being two recent examples. The key is to develop a long-term policy and associated incentives that learn from best practice elsewhere. A shining example of how to do this through the provision of funding and support is the Kreditanstalt für Wiederaufbau (German Development Bank).[17] Conversely, SMEs with whom we work are displeased at the inconsistency of UK legislation, associated schemes, and messaging. A solution would be a unified scheme to provide consistency and stability. Connected with this is the need for accredited training of all those involved in the chain of refurbishment. Low carbon refurbishment literacy remains low and demands immediate remedial action. The Retrofit Academy, the National Centre of Excellence for Retrofit, is doing excellent work in championing the skills required for upgrading of existing buildings.


21. There are several other measures that could also be taken. There also needs to be freely available honest broker advice for customers & all elements of the supply chain. Householders need advice from someone who is not trying to sell them their solution, although it is an open question as to who dispenses this advice and who pays for this whole process. The extension of the Minimum Level of Energy Efficiency Standard for privately rented properties to owner occupier properties too, at point of sale, would be a significant and positive step. Our research also shows a focus on a number of key events in the course of home ownership/occupation could be an effective approach to encouraging positive action, for example the birth of a child, buying a first home, moving home, or retirement are important nodes in this process.[18] In addition, the annual interaction with the heating engineer at annual boiler service is potentially a powerful opportunity for encouraging a focus on sustainable energy.


22. Throughout, the imperative remains to ensure that the embodied carbon of repair, maintenance and retrofit is fully minimised.


23. The application of VAT to refurbishment projects moves the market away from the adaptation and re-use of buildings towards new build, with consequential additional energy use and resource efficiency implications.


24. Innovation and the rapid introduction of lower embodied energy and more energy efficient products to both the new build and refurbishment markets is inhibited by the cost of product testing. Testing and certification from for example, BBA Agrément and NHBC warranties, are required to secure approvals and mortgages. Support for testing of products could potentially accelerate innovation.


May 2021










[8] Lowfield Timber Frames (LTF), ( a Shropshire based member of the University of Wolverhampton’s BECCI Innovation Incubator is a highly eco-aware business with a good understanding of Environmental Product Declarations (EPD). However, until recently there has been no demand from clients for EPDs. April 2021 marked the first time an LTF customer had asked for an EPD.

[9] There is evidence from industry that the use of wood within the structural fabric of buildings is becoming more challenging. Lowfield Timber Frames reports that the uncertainties about the fire safety of wood and the ban on combustible materials in some buildings is causing uncertainty.








[16] Veritherm have established that new-build houses regularly miss thermal efficiency standards by between 200 and 300%. The fuel bills and the CO2 emissions associated with them are accordingly 2.6 times greater than expected, on average. Thermal performance is a vital factor in reducing emissions from housing.  Insulation, ventilation and high-performing components such as windows and doors are specified and need to be correctly installed in order to generate a return on green stimulus investment.  The thermal “performance gap” is therefore a major problem.  What is needed is a method to assess if a building has the thermal performance that is specified by its design data. The main aim of this is to ensure compliance with design at the hand-off between construction and management of a building, although it can be used at other times, e.g. checking the effect of a major re-fit or detecting unauthorised modifications. The Veritherm platform has been developed to address the problem of the performance gap and to provide the building industry with a straightforward way to verify thermal performance.  The Veritherm digital system uses a network of sensors and loads (electric heaters and fans) to determine whether the thermal performance of a building is within expected bounds compared to the design aims. Data is uploaded to the cloud and analysed automatically, with the proprietary algorithms returning a definitive answer overnight.