Elliott Wood Partnership Ltd                            SBE0092

Written evidence from Elliott Wood Partnership Ltd

[0.1] Written evidence submitted by: Elliott Wood Partnership Limited. Elliott Wood are Consulting Engineers specialising in structural and civil engineering, transport and BIM management, and sustainability with an over-arching purpose to Engineer a Better Society.

[0.2] We have responded to all 10 questions posed by the enquiry below.

[0.3] For over 25 years, Engineers at Elliott Wood have been designing and making things better.  Climate, economic and societal change all heightened by a pandemic have created a much bigger broader challenge.  We have to start to do better things.  In harnessing emerging digital technology and adopting greater empathy, Engineers can discover and drive innovative solutions that will have an impact.  We call this Engineering a Better Society. To help us we have written a manifesto, ETHICS, and created a workplace, both digital and physical, called The Building Society. We started with low carbon design but circular thinking is the new normal and runs through every aspect of what we do. Strategic links with industry and academia are supporting our research and thinking. It is for this reason, we are submitting evidence to this inquiry.


[1.0] Question 1. To what extent have the Climate Change Committee’s recommendations on decarbonising the structural fabric of new homes been met?

[1.1] The components of new homes specified by Civil and Structural Engineers today account for about 60% of the embodied carbon the moment an owner walks through the front door.  Since the declaration of a climate crisis and assertions to change and meet NZC targets little has changed.  A large proportion of our work is across London and walking through London’s Boroughs it is easy to see what we are building and how.  Our experienced engineers’ eyes witness lots of concrete frames for almost everything and brick and blockwork for low rise.  Even the trained eye finds it hard to find even the green shoots of a construction revolution embracing low carbon materials and methods.  The reality makes for much poorer reading with the UK adopting a go slow/go backwards approach to finding ways of building safely with timber.  The London local Authorities seems to have a comprehensive ban on anything remotely plant based! 

[1.2] There may well be statistics showing that change is happening.  The reality is that it does not look like it, because there is no change.  The supply chain is the same, the skill base is the same, procurement is the same and most importantly the large house builders who control the market are carrying on as normal. 

[1.3] Fortunately, the market is changing fast, and the customers will ultimately decide what they will be buying or more likely what they are prepared to rent and where.  Household names have disappeared from our High Streets as they failed to adapt to changing habits and technology.  It would be a brave person to think the UK housing industry will not end up in similar peril.


[2.0] Question 2. 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?

[2.1] The construction industry has in previous years focused mainly on more energy efficient buildings, i.e., operational carbon. This subsequently means that the proportion of the building’s lifecycle carbon that comes from the embodied carbon becomes more significant because of the shift towards decarbonised grid. This is where material choice in the structure and in the finishes becomes more prevalent.


[2.2] We have found as a practice through our embodied carbon calculator & researching the re-use market for construction materials, that the most effective way to reduce embodied carbon emissions is by re-using second-hand materials before considering low carbon materials.


[2.3] The above diagram shows the hierarchy of saving materials which we have adopted.

[2.4] The committee should be asking instead, How should material re-use be used to reduce the carbon impact of new buildings…”

[2.5] When looking to build, clients & design teams need to consider the following:

-         Reuse existing buildings,

-         Build using less materials,

-         Build using certified recycled materials,

-         Build using low carbon materials,

-         Build using long lasting and durable materials, designed for easy disassembly,

-         Build flexibly and for future adaptability to allow for the re-purposing of buildings.


[2.6] A lot of work has been undertaken by the construction sector in the UK and across the world to understand the embodied carbon of construction materials.


[2.7] Within the UK, the University of Bath has created the “Bath Inventory of Carbon Energy (ICE), an open-source database of embodied carbon emissions of building materials. The database which contains over 200 materials, is heavily relied upon by the industry to provide data as part of the embodied carbon calculation.


[2.8] In Denmark, the Construction Material Pyramid has been developed by the Centre for Industrialised Architecture at The Royal Danish Academy of Architecture, Design & Conservation. The pyramid clearly demonstrates the hierarchy of various materials used within the construction industry.


[2.9] There are some very high embodied carbon materials that are used widely across the industry including but not limited to aluminium, steel, cement, and some plastic based materials. In order to reach the Governments commitments of NetZero by 2050, the reliance on virgin forms of these materials needs to be regulated & reduced to ensure targets can be met.


[3.0] Question 3. What role can nature-based materials can play in achieving the Government’s net zero ambition?

[3.1] The best materials out there which are widely available in construction are: Timber, Bamboo, Lime, Slate, Rock, and Clay. These materials were originally the building blocks of the Industrial Revolution, and the manner in which we now work with them is less carbon intensive and better understood, making them more reliable to work with structurally.

[3.2] Currently in the existing building stock, there is a lot of timber used mainly for floor construction. We are currently tracking a research project undertaken by CirCUIT and Grimshaw Architects to explore Cross-Laminated Secondary Timber & Glulam, both are created using waste timber. Successful trials will provide further confidence in using second-hand materials within the construction industry.

[3.3] There are some other nature-based materials that have very low or negative embodied carbon values which provide insulation to buildings such as Mycelium. This is a fungus material with equivalent properties & fire resistance to modern day insulation products.


[3.4] Timber and Bamboo remove carbon from the atmosphere as they grow and so could be used to ‘lock’ carbon into the building for the duration of its lifespan and beyond.


[4.0] Question 4. 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?

[4.1] Ultimately, it is the end user that needs to be driving the agenda, and not developers. Developers are providing a product in a commercial transaction, and therefore financial gains will govern their decisions. It is the end-user, the building occupiers, who will decide what they are happy to buy or rent. This will guide the developers. Therefore, engage with the general public to understand what they want, and don’t listen to the developers.

[4.2] Built environment professionals have been discussing the potential to regulate embodied carbon emissions since the 2007 Sullivan Report. In 2014, the Embodied Carbon Industry Task Force, a group set up to ensure that embodied carbon would be considered in building design and to build a consensus on how it would be measured and reported, recommended that embodied carbon be included within the Zero Carbon Building regulations. Unfortunately, in 2015 The Government scrapped the plans for these regulations, and with it closed this route to embodied carbon legislation. This needs to be reintroduced.

[4.3] In the UK, six key routes to introduce policies should be considered:

- Building Regulations,

- National Planning Policy,

- Local Planning Policy,

- Design Standards,

- Public Procurement,

- Tax Rules.

[4.4] The Carbon Neutral Cities Alliance & Bionova Ltd (2020) “City Policy Framework for Dramatically Reducing Embodied Carbon” document should be referred to for ideas of policies which could be introduced at national and local level.

[4.5] To ensure the industry can reach meet the targets, a phased approach needs to be considered. Whereby, targets are set for every five years, which will help the industry push to lower their carbon footprint.

[4.6] Assessment should be required at a number of stages and mandated within Building Regulations, National Planning Policy Framework & Local Planning Policy. This would bring embodied carbon emissions into the UK’s building standards framework and in-line with considerations of operational energy use.

[4.7] When the regulation is fully implemented, new buildings would need to be designed, constructed, and operated to not exceed established whole life carbon or embodied carbon limits. These limits should then be reviewed regularly and continually reduced as we move towards 2030 & 2050.


[5.0] Question 5. What methods account for embodied carbon in buildings and how can this be consistently applied across the sector?

[5.1] As detailed below, standardised methods have been in place since 2011. The industry is equipped and ready to act. What is missing is appropriate legislation.


[5.2] Below is an outline of the methods available to designers and when they were introduced:


-       [5.2.1] In 2011, the framework by which a building’s lifetime environmental footprint, should be calculated and communicated using a Life Cycle Assessment was set out by the British Standard BS EN 15978:2011. This standard is applicable to all new and refurbishment building projects.


-       [5.2.2] In 2017, RICS defined the scope and methodology for carrying out WLCA with the publication of “Whole Life Carbon Assessment for the Built Environment.” This document explains that taking a whole life cycle approach, considering both operational and embodied emissions in parallel, is the most effective way to truly understand and lessen a building’s carbon footprint.


-       [5.2.3] In 2019, RIBA published embodied and whole life carbon assessment guidance for architects.


-       [5.2.4] In 2020, the IStructE published their guide; ‘How to Calculate Embodied Carbon’, which standardised the carbon data for key structural carbon data for the main structural materials and provided a developed methodology based on the above standards.


-       [5.2.5] In March 2021, Elliott Wood and the IStructE launched: The Structural Carbon Tool, a spreadsheet-based tool, aligned with the guide noted above. It was donated to the construction industry for free, for use by anyone who wishes to use it with a view to positively impacting the climate emergency.


[5.3] At Elliott Wood we have been measuring embodied carbon on our projects for the past five years and since the publication of RIBA and LETI targets, we have been measuring our projects against these targets to continually improve our designs with respect to minimising carbon. We are not alone, many other structural engineering companies are doing the same.


[5.4] It should be noted that in its June 2020 “Progress Report to Parliament”, the Committee on Climate Change recommended that government support should be given to the “assessment and benchmarking of whole life-cycle carbon emissions in buildings”, before the end of the year. Rather than disputing the importance of this recommendation, the Government’s response positions that such commitment would not be possible without a standardised method of calculation supported by a robust evidence base. As noted above, a standardised method has been in place for a decade, making this response ill-informed.


[6.0] Question 6. 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?

[6.1] Yes.

[6.2] Within the methodology of Whole Life Carbon Assessments (WLCA), the carbon cost of manufacture and delivery is taken into account. The WLCA details various stages of a material, with Module A covering Product Stage and Construction Process.

[6.3] Product Stage includes:

A1: Raw Material Supply

A2: Transport

A3: Manufacturing


[6.4] Construction Process:

A4: Transport

A5: Construction Installation Process.

[6.5] In order to assess the carbon impact of a building, a WLCA is required to be undertaken, and therefore for any “Alternative Building Materials” to be considered, the above stages will need to be accounted for.

[6.6] The Structural Carbon Tool launched by the IStructE and Elliott Wood in March 2021 includes the functionality for users to calculate their own A4 transportation values based on the specifics of where their project materials are being sourced. UK averages are also provided for the common construction materials.


[7.0] Question 7. How well is green infrastructure being incorporated into building design and developments to achieve climate resilience and other benefits?

[7.1] The greatest challenge to the behaviour and infrastructure changes required to achieve net zero carbon is the perceived cost and convenience to the target market. As an example, due to COVID more than half of the UK population are classed as financially vulnerable, thus individuals are more likely to be concerned with making ends meet, than switching to electric cars. Policy and funding will therefore be key to support this transition.

[7.2] From a policy perspective, London is paving the way. The Mayor of London’s Transport Strategy and New London Plan 2021, have set out plans to transform London’s streets, improve public transport, enforce Urban Greening Factors and put walking and cycling on top of the transport agenda. With this in mind, other local councils should be made to take on board and mimic London’s efforts towards green infrastructure.

[7.3] The assessment of major developments using a ‘Healthy Streets’ methodology has been a welcome change in the way transport impacts of developments are considered in the capital.

[7.4] Whilst it is imperative sufficient cycle parking is provided, it is unsustainable to provide excess cycle parking that will never be used, particularly when these are often provided in basements (with a huge carbon footprint.)

[7.5] Ultimately though, the best way to go forward is to not build new at all. The sustainable methods of infrastructure are only employed because new structures are being built, which are currently carbon-intensive, and in reality, are not sustainable.


[8.0] Question 8. 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?

[8.1] Though this question focuses on Operational Carbon, as has been identified by a number of action groups and committees across the country and internationally, the carbon emissions which arise from the construction of new-building materials is mainly Embodied Carbon. Many examples on this have already been given.

[8.2] With constant improvements being made in renewable energy, the operational energy of a building will continue to become more decarbonised, however little improvements have been made in embodied carbon other than the industry’s ability to quantify the carbon emissions.


[9.0] Question 9. How should re-use and refurbishment of buildings be balanced with new developments?

[9.1] From a pure embodied carbon perspective, we have to work with what we have and minimise new construction. We cannot build our way out of the climate emergency because to build anything new costs carbon. There are strong operational carbon reasons why demolition and new build can make sense but these should not hold more weight than embodied carbon, a whole lifecycle approach is required.

[9.2] Refurbishment or repurposing of existing buildings should always be the first solution explored on any site with an existing building.

[9.2] Currently, there is an imbalance within the industry, with a preference for new-development, overlooking the ability to refurbish an existing building, as the current financial gains are greatly in favour of building a-new.

[9.3] With regard to re-use, the construction sector is not set up for a re-use market to be financially viable for clients to consider as an option currently. Currently, there is a small percentages of traders who specialise in the re-sale of existing materials (bricks & timber), however these companies are small enterprises, who are ill-equipped to meet the demands of large construction projects.

[9.4] Working with the Grosvenor Group, Elliott Wood has produced a detailed guide on the deconstruction of buildings for circular re-use. The guide outlines a 12-step guide to make Re-use the norm for the construction industry. An actionable framework to help architects, developers, contractors and demolition firms take steps to implement re-use on their schemes. The guide includes a methodology to assess the Re-use potential of building materials in four streams of work:

-       Data collection to establish the building layout.

-       Non-destructive investigations to determine the structure behind the finishes,

-       Inventory and structural sketches of the individual elements of the structure

-       Evaluation of Re-use potential of steel, timber, masonry, and concrete elements.


[10.0] Question 10. What can the Government do to incentivise more repair, maintenance and retrofit of existing buildings?

[10.1] Due to the slow bureaucratic approach to legislation, the Government are not acting quick enough.

[10.2] Currently there is a taxation on refurbishment of properties (20%) and this is a critical hurdle which many clients fail to clear when weighing up commercial viability. We pay 20 per cent VAT on most forms of refurbishment and renovation and typically between 0 per cent and 5 per cent on embodied carbon-guzzling new build.

[10.3] Therefore, the government should look to:

-         [10.3.1] Incentivise material re-use and introduce a carbon tax on new builds and virgin materials,

-         [10.3.2] Incentivise for the establishment of second-hand markets e.g. tax rebates / reductions in corporation tax / grants for setting up businesses,

-         [10.3.3] Change planning law to make it incumbent on the building owner to justify why they are not retaining an existing building before any new build project is granted planning,

-         [10.3.4] Targets within Building regulations e.g. embodied carbon targets or material re-use targets,

-         [10.3.5] Requirements for in-use post occupancy evaluations; the success of which are linked to building rates / council tax band.


[10.4] The end goal of these new tax revenue streams is to help the industry wean itself off current bad habits.


[10.5] The committee should take note as to how capital funders are responding currently to the Environmental Social Governance, such as BNP Paribas & JP Morgan, and how they are responding to the changing demands of the younger generations. They have recognised that it matters to the new wave of future generations, more so than ever, that things worthy of investing in are demonstrably sustainable.


May 2021