Written evidence submitted on behalf of the Royal Institution of Chartered Surveyors
Introduction and Context
- The Royal Institution of Chartered Surveyors (RICS) is pleased to respond to this Call for Evidence by the Environmental Audit Committee inquiry into the sustainability of the built environment.
- Established in 1868, RICS is the largest organisation of its kind for professionals in property, construction, land, and related environmental issues, setting and upholding professional standards for 125,000 qualified professionals and over 10,000 firms. RICS regulates both its individual qualified professionals and those firms that have registered for regulation by RICS.
- Over 80,000 of our qualified professionals work in the UK, where our goal is to deliver a healthy and vibrant property and land sector as a key pillar of a thriving economy.
- We are not a trade body; we do not represent any sectional interest, and under the terms of our Royal Charter the advice and leadership we offer is always in the public interest.
- A recent report, published by the International Energy Agency (IEA), discovered that around the globe, 36% of final energy use and 39% of energy process-related carbon dioxide resulted from the buildings and construction sector . A third of which resulted from the manufacture of building materials, underlining the importance of monitoring all emissions throughout the lifecycle of buildings not just in use.
- RICS has been involved in attempting to bridge the data gap apparent in the construction sector with all matters regarding embodied carbon and energy efficiency in buildings. RICS’ involvement in the European Building Stock Observatory project, an initiative of the European Commission demonstrated that there are significant gaps in energy performance data of buildings across the EU and the UK.
- Reliable data regarding embodied carbon and energy performance is still hard to come across. It could be argued the main reason behind this is because there is no measurement or monitoring requirements coupled with a lack of an agreed consistent methodology in industry.
- Considering the significant burden emissions from construction and buildings demonstrate in terms of national final energy use and energy process related carbon, measurement, monitoring, and reporting are crucial.
- Emissions from the production and construction process stage should be measured as soon as practicable, as they are generally responsible for 55% of the whole embodied carbon emissions  through the lifecycle of a typical construction project and will be emitted before 2050 (Annex 1).
- The embodied carbon methodology presented in this paper provides a structure for effective reporting and monitoring by building upon the most significant standards and measuring methodologies in the sector.
- The methodology developed by the Institution of Structural Engineers (IStructE) allows a precise reporting framework thanks to the granularity of measurement and presents an opportunity to reduce the burden of measurement by providing a stratified approach.
- RICS also argue, that any components installed through retrofits, should also be measured using the same methodology to ensure accurate and consistent measurements of total environmental improvements.
- The planning system and Permitted Development Rights (PDRs) could also be used as a powerful tool so long as they include provisions for embodied carbon, to incentivise improvements to existing buildings, or redevelopments.
- What methods account for embodied carbon in buildings and how can this be consistently applied across the sector?
- Efforts have been made across the industry to provide a standardised methodology. In the UK, some documents of importance are BS EN 15978, BS EN 15804, RICS Professional Statement Whole life carbon assessment for the built environment , and the IStructE’s How to calculate embodied carbon . However, although efforts in measuring embodied carbon have been available for over a decade, access to reliable data is still proving to be difficult. Both the RICS Professional Statement and the IStructE report could serve as a potential methodology for the effective measurement of embodied carbon.
- The methodology developed by IStructE builds upon the RICS Professional Statement providing an efficient method to measure embodied carbon. According to BS EN 15978, the construction process is divided into 14 different modules depending on the project stage. A1 – A3 are the product stages where measurement is done from the raw material extraction and supply through to the manufacturing and fabrication of products. A4 – A5 is the construction phase, where carbon emissions are measured from the transportation of materials onto the site through to the end of the construction and installation process. B1 – B7 is the in-use phase, where all carbon emissions produced throughout the use of the structure are measured including repair, maintenance, and refurbishment. C1 – C4 measures the emissions of the end-of-life stage and module D considers the possible benefits the structure could have beyond its end of life by either reusing or recycling items.
- The methodology considers the modules A1 – A5, B4 (for facades) and B6 as the minimum scope for calculation of embodied carbon. The reasoning for this is that, for new builds, A1 – A5 emissions will be released before 2050, and therefore understanding and abating these emissions is crucial to meet the climate change targets. Furthermore, most of the embodied carbon of built structures is created in modules A1 – A5.
- To ensure comparability between embodied carbon measurements, users of this methodology should utilise and report it against the Building Cost Information Service’s (BCIS) Elemental Standard Form of Cost Analysis (SFCA) element categories. Utilising this standard, could also permit for embodied carbon to be reported alongside costs which would allow industry to consider both cost and embodied carbon together in the decision making process.
- Having a stratified methodology decreases the data collection burden of monitoring emissions throughout the lifecycle of a building as well as permitting a more detailed measurement of emissions on a stage-by-stage basis. This will also facilitate increased comparability between sustainability solutions.
- Providing a standardised methodology, backed by policy, and requiring monitoring and reporting to a central database is crucial to understand the true challenge faced. RICS is currently collaborating with important actors across the industry to develop an embodied carbon database to help the availability of consistent data and metrics.
- The methodology should be flexible to consider emissions at the various stages of construction and allow input from the wide range of actors involved in the construction lifecycle.
- 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?
- Definitely, given our point in paragraph 5. When benchmarking carbon impact of alternative materials compared to traditional resources, the same methodology for measuring emissions should be applied. This would assure comparability between materials therefore allowing identification of which solution has the least environmental impact.
- What can the Government do to incentivise more repair, maintenance and retrofit of existing buildings?
- The government should utilise financial instruments in order to incentivise repair and retrofitting of existing buildings as long as the works are designed to extend the use of the building and do not produce more carbon than at the end-of-life stage. By retrofitting existing buildings, actors would be avoiding the carbon emissions from phases A1 – A5 and C1 – C4 as well as extending the in-use phase. However, it is important to make sure the refurbishment would make the building future proof, as performing renovation after renovation may in the long run be worse in terms of embodied carbon as items become obsolescent. For this reason, it is important that the incentives designed by the government require information on the performance improvements (in terms of EPC improvement), an estimation considering the next required renovation, as well as the embodied carbon included in the refurbishment (similar to the Building Renovation Passports ).
- To incentivise repair, maintenance and retrofit, the government could either, reduce/remove VAT for items and labour utilised in performing the necessary works in existing buildings or alternatively create targeted grants based on the EPC rating of the buildings. Less efficient buildings should be targeted as a priority to decrease the emissions produced whilst using the building i.e. EPC C and below.
- We recommend that both incentives are considered. However, as the grants are likely to be limited, only buildings that have a strong potential of improvement and which currently pose a true financial burden on their owners should be considered. The grant system should be used as a tool to help owners in lower income earning households that do not have the financial capacity to renovate their properties.
- 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?
- As mentioned in paragraph 15, it is crucial that all items either in the materials or systems are measured with the same methodology as other building items. Considering that these systems will likely reduce the carbon footprint of the building in the in-use module (B1 – B7), particularly B6 and B7, their potential increases in sustainability will already be accounted for in the methodology.
- Other than the potential benefits these systems may have regarding increasing the sustainability of buildings, some technologies’ benefits may not be bound only to the building. For example, the installation of solar panels on a building, will not only increase the sustainability of the building by decarbonising its energy use, but could benefit other surrounding buildings as well as the electricity grid. If a building generates more electricity than it utilises in a day, it would be possible to feed this electricity back into the grid, allowing surrounding buildings to benefit from the use of clean electricity. Additionally, by generating electricity at the source of demand, we are also preventing transmission losses. This is important as UK power Networks estimated that in 2017, carbon emissions attributable to transmission losses alone represented 2% of the national emissions.
- 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?
- Although building regulations already include provisions for building sustainability, PDRs do not yet. PDRs are a powerful tool when considering the conversion of a building from a non-residential use to residential use and have had a widespread take-up. Since August 2020, further relaxation of PDRs allows for buildings to be demolished and replaced by blocks of flats within the original footprint of the old building.
- Provisions regarding sustainability should be added to PDRs requiring redevelopments to also consider sustainability, by utilising materials with a smaller carbon footprint or by making significant energy efficiency improvements. Where possible, these potential scenarios should be measured and presented to the authorities with the methodology discussed previously, allowing for comparability between project outcomes.
- If a proposed project does not involve demolition and redevelopment but simply a refurbishment project, then developers should be encouraged to consider energy efficiency improvements to the current requirements of the building regulations.
- How should re-use and refurbishment of buildings be balanced with new developments?
- There should be a priority given to re-using and refurbishing buildings if this has the least environmental impact both in the short and long term.
- Historic or traditionally constructed buildings must be considered by those with specialist competence when considering alterations or refurbishment, as these buildings are often hard to treat, and poorly designed retrofit solution can have very damaging consequences.
- An assessment or rating system could be developed to balance the value of retaining existing buildings (both on a carbon, social and aesthetic basis) versus replacement. The carbon element of retain against rebuilding could be calculated using the methodology mentioned in the previous points (paragraphs 7-15). However, social impact can be difficult to quantify and would require the involvement of the community and due planning considerations.
- Where replacement is preferred by developers, but not advantageous on a carbon basis, only high-quality schemes, meeting enhanced design criteria as well as consideration for social wellbeing and utmost sustainability would be allowed.
 IEA 2019 Global Status Report for Buildings and Construction
 Royal Institution of Chartered Surveyors – RICS Professional Statement Whole life carbon assessment for the built environment
 The Institution of Structural Engineers – How to calculate embodied carbon
 UK Power Networks’ Distribution Losses Strategy July 2019
 European Building Stock Observatory
 Building Renovation Passports – Customised roadmaps towards deep renovation for better homes
Annex 1 – Life cycle stages and modules as defined by BS EN 15804 (as presented in IStructE “How to calculate embodied carbon” report)