Dominic Eley                            SBE0109

Written evidence from Dominic Eley


[1.0]              My name is Dominic Eley, a recently qualified architect, currently working at Buckley Gray Yeoman, a medium-large architectural practice based in Central London. Throughout my 7 years of architectural education, sustainability was barely mentioned beyond a single module undertaken at the University of Nottingham in first year. With a strong interest in sustainability and the built industry I find this particularly distressing, that a large proportion of students having paid a small fortune to attend university are barely receiving a critical education that will (hopefully) become such an intrinsic part of their practice.


[2.0]              Similarly, now I find myself in architectural practice, sustainability is not at the forefront. Projects that have a focus on sustainability are based on the good will of those involved, or due to requirements from funders, rather than being based on regulation or legislation. As such, for many projects, a sustainable outcome is not achievable - a major issue whilst in a climate emergency. We are working on projects that will not be completed until between 2025-2030, yet there are currently no national regulations to limit the embodied carbon emissions of these schemes. This has to change.


[3.0]              As a member of the ACAN Embodied Carbon Group (ACAN EC), I have been part of their on-going campaign to regulate embodied carbon. This thematic group has worked hard to develop a succinct and manageable way in which a key question of this audit, ‘What methods account for embodied carbon in buildings and how can this be consistently applied across the sector?’ can be answered. ACAN EC are proposing that embodied carbon is regulated at a national level, through Building Regulations and planning policy by making Whole Life-Cycle Carbon (WLC) Assessments mandatory and introducing limits on WLC emissions - a strategy to actively cover two distinct approaches to the reduction of embodied carbon from buildings: tackling carbon emissions in construction, repair, and maintenance and further in time during demolition, disposal of waste, and re-use of material.[1] Further detail and a recommended timeline of key steps can be found at


[4.0]              I am responding to the Environmental Audit Committee on the lack of over-arching legislation to require the calculation, and ultimately management of embodied carbon emissions. ACAN have outlined several policies, informed by the Carbon Neutral Cities Alliance & Bionova Ltd (2020) “City Policy Framework for Dramatically Reducing Embodied Carbon” document, that are applicable to the UK context and should be adopted within national or local policies, to reduce embodied carbon emissions. These are summarised below with further detail in ACAN’s report[2]. Where appropriate, examples, either UK or international are made reference to.


[5.0]              Embodied Carbon Targets for Designated areas of development (Policy Z1)

A local regulation that can be adopted through a local plan and supplementary planning guidance (SPG). This Policy would require the assessment of development areas based on the potential carbon impact, taking in account soil conditions and building typologies, as well as transportation and energy use. This would help to reduce the upfront carbon emissions for materials, energy use and transport. This Policy could be managed through the EN15978 / ISO 21930 compliant evaluation, identifying to local authorities whether proposed development sites are in line with embodied carbon targets, prior to development taking place. Examples of this measure have been adopted in Norway, Finland and the UK.



[6.0]              Bio-Based Materials for Designated areas of development (Policy Z2)

A local regulation that can be adopted through a local plan and supplementary planning guidance (SPG) introducing a requirement for the use of low carbon impact materials in designated development areas based on building typologies. This would help reduce carbon emissions and increase carbon storage, helping to encourage the timber industry in the UK; building frame and facade predominantly made of sustainably sourced wood allowing for disassembly and reuse of wooden elements in other buildings through the use of reversible connections / fixings other than adhesives, or by incorporating a minimum value of biogenic carbon storage in all permanent structures and materials. This could be incorporated at the planning stage to demonstrate compliance. This policy is currently being used in Helsinki, where all buildings in the district of Honasuo are required to have wooden frame and facade, and all detached houses to be built with massive wood. Likewise, Vorarlberg in Austria provides grants for new houses demonstrating low embodied and low operational carbon. In order to be eligible, projects should not include materials that are considered carbon intensive.



[7.0]              Carbon-scoring of local authority land for sales or to be leased (Policy Z3)

A local regulation that can be adopted through competition and contract/tender rules, whereby bids for the purchase or long-term lease of land owned by local authorities can be scored against a life-cycle carbon efficiency criterion, with bidders required to declare the carbon impact of their proposals. Verification by a third party is conditioned as part of the tender and on the development completion with the tender rejected or a financial penalty if work fails to meet declared targets. This places significant power to local authorities to determine the carbon impact of buildings, leading developers to compete on the most carbon efficient concept development. The bid scoring could place emphasis on carbon e.g 30% of the total score, as evidenced in the City of Porvoo in Finland.



[8.0]              Life-cycle carbon limits for new buildings (Policy R1)

              National and local policy that could be adopted across Local Plans, Building Regulations and National Planning Policy to ensure new buildings are designed, constructed and operated to not exceed established whole life carbon, or embodied carbon limits. This whole life carbon limit drives the project team to interrogate all life-cycle stages beyond simply the upfront embodied carbon emissions to achieve practical completion. This promotes early stage awareness of carbon-saving methods such as the use of structural timber and structural grid spacing, as well as an awareness of maintenance impacts and demountability, feeding into a circular economy. This would involve accounting carbon according to a nationally recognised standard, helping provide benchmark data for future projects, as well as analysis of this data. This information could be submitted through the planning process, incrementally making targets more stringent and introducing penalties over time, giving the industry time to respond. In Douro-Dummer, Canada, in order to support the adoption of their Sustainable Development Guidelines, grants were available for the first 50 applicants whose projects achieved the carbon emissions target.



[9.0]              Limiting the Environmental Damage from Concrete (Policy R2)

              A national policy that could be applied through the building regulations, requiring the volume and greenhouse gas emissions from concrete to be reported against set limits. All new and refurbishment projects would be required to report on the total volume of concrete proposed to be used, as well as its EPD (Environmental Product Declarations) data. Alongside benchmarks, the amount of concrete used and its environmental performance would be reported, ultimately leading to a reduction in its use. Examples of policies relating to the regulation of concrete use can be found in California,[3] Oregon, Singapore and Norway.



[10.0]              Material-efficient Structural Design Requirement (Policy R3)

              A national policy that could be introduced to Part A of the building regulations, as well as any public procurement rules, to improve the efficiency of a building’s structural design in order to reduce material use and therefore lower embodied carbon. Structural elements in the UK (as in many other countries), are commonly overengineered. The use of digital design tools can offer opportunities to reduce this excess, through analysis, testing and fabrication. All projects over a certain size to submit a Structural Materials Quantities report and an Average Utilisation Ratio for the whole project as part of a planning application, helping deduce benchmarks. A similar policy exists in US cities, including in San Francisco, Los Angeles and Seattle.



[11.0]              Declaration of construction materials carbon efficiency (Policy R6)

              A local policy that could be introduced to the SPG requiring any new development or refurbishment of an existing building to declare structural and building envelope material efficiency, for example as kg/m2 GIA. In parallel, projects to provide materials passports and/or EPDs, including details on how products/components are to be installed. This would add to benchmark data on building materials, as well as support the development of a local circular economy, helping to keep a record of materials used across the local authority area and encourage their reuse. Currently a similar policy and platform is being developed in the Netherlands to drive the circular economy.[4]



[12.0]              Life-cycle carbon calculation and reporting (Policy R9)

              A national policy that could be incorporated into the building regulations, as well as national and/or local plans to introduce a requirement for any new development or refurbishment to calculate and report whole-life-cycle emissions using a standardised methodology. This would help develop greater understanding of carbon impact at all life-cycle stages, improve familiarity with the assessment methodology and build a database for benchmarking and future targets or regulations. Significant reductions in operational carbon emissions have been achieved through the building regulations. However, these only account for around 30% of a new building’s total lifetime emissions, with the other 70% coming from embodied carbon emissions.[5] This policy would require all new or existing projects requiring planning permission for development, extension or retrofit to complete a whole life-cycle carbon assessment to be submitted as part of the planning application process, for building regulations approval, and again at practical completion. Policy SI 2 in the new London Plan is an example of this type of policy applied at a local level.



[13.0]              Carbon Limits for Key Materials (Policy P1)

A national policy that could be introduced to public procurement rules to require EPDs to be submitted for specific material types for public projects, alongside limits for each of these products related to Global Warming Potential. Many common materials used for construction (glass, steel, concrete, insulation, gypsum board and refrigerant) might have different global warming potentials depending on how they are extracted, manufactured and transported. EPDs can be used to assess this and local authorities could lead the way in driving the market towards increasing the number of EPDs available. As the industry decarbonises, the caps on GWP for each of the products can be lowered. The Buy Clean California Act is an example of this policy in use.[6]



[14.0]              Whole Life Carbon evaluation of Retrofit versus Redevelopment (Policy M6)

              National and local policy that could be incorporated into national frameworks and local plans requiring the carbon emission comparison of retrofit versus demolition and redevelopment. The UK loses more than 50,000 buildings each year to demolition[7], which could have instead been part of our low carbon future. Mandating WLC studies will drive project teams to undertake comparative whole life carbon studies to highlight the carbon emission savings possible through building reuse, in doing so, promoting this sector of the industry. The planning process could require two life-cycle assessments; one of reuse and one of demolition and new build, based on nationally recognised carbon accounting methodologies. Audited by local authorities, this data can be used to develop industry benchmarking and encourage retrofit. Another first step to promote building reuse would be to reduce the VAT rate of 20% applied to refurbishment, repair and maintenance to at or below the level applicable for new build developments.



[15.0]              Salvaged, Reused or Recycled Material Minimums (Policy M7)

A policy applicable at a local level through public procurement, with Local Authority construction projects required to meet minimum levels for the use of salvaged, reused or recycled materials. Local authorities could also introduce incentives for private sector projects within their boundaries if these meet the same criteria. This policy would reduce the embodied carbon emissions of individual projects, help drive the circular economy through the support of supply chains, while creating jobs, and reduce waste to landfill. Requirements could be introduced at an individual material level, or at a project level, measured as a percentage of total material use. A similar policy is in place in Los Angeles County where The Metropolitan Transport Authority requires that preference is given to recycled and recyclable products for their projects.[8]



[16.0]              Increasing demolition permission fees (Policy F6)

A policy applicable at a national or local level, through the National Planning Policy Framework and Local Plans. Planning permission to be required for the demolition of all buildings, and fees applied depending on the building’s age, suitability for reuse or deconstruction and material reuse. Increasing the financial cost of demolition will incentivise property owners and developers to fully evaluate alternatives to demolition such as low carbon and adaptive retrofit. A co-benefit of this policy would be for the additional fees to contribute towards an improved deconstruction industry with improved material reclamation and salvaging procedures to support our needed transition to circular economies.



[17.0]              In the UK pre-existing policies directly relating to embodied carbon can only be found at local level within local authority planning policy. As it stands, the Greater London Authority (GLA) and, to a lesser extent, Greater Manchester, require large developments to measure and report embodied carbon emissions, through whole life carbon assessments, and demonstrate viable efforts have been taken to reduce them. However, this requirement is not enshrined in national policy, marking a clearcut standard for the way in which embodied carbon is controlled and managed.


[18.0]              The GLA looks to manage embodied carbon through Policy SI 2 of the London plan, a requirement for developments to calculate the embodied emissions of referable developments, as well as the operational emissions and demonstrate how these can be reduced as part of the Whole Life-Cycle Carbon Assessment. Whole life-cycle carbon assessments are currently only required for referable schemes, meaning a significant number of projects are still not required to measure, reduce or even understand the true extent of their embodied carbon emissions. London boroughs have the option of applying this policy to a wider range of construction projects, and it is looking increasingly likely that some London boroughs will apply the policy to all major schemes. This policy is a great first step towards tackling embodied carbon emissions, however, due to the limited scope of projects to which it applies there are still a huge number of proposed buildings that are not being regulated in terms of their embodied carbon impacts.


[19.0]              Greater Manchester have also made reference to embodied carbon at a local level. The Draft Manchester Zero Carbon Framework 2020-2038 highlights that “new buildings need to generate zero emissions when occupied and have significantly less emissions embodied in their materials and the construction phase.”[9] Similarly, the Carbon & Energy document reports that the Greater Manchester Spatial Framework needs “to adopt a whole life-cycle approach to carbon emissions to consider both the operational and embodied carbon resulting from new development.”[10]


[20.0]              Although both the GLA and Greater Manchester show promise in their commitment to deliver on embodied carbon, they are not aligned in their detail, benchmarks or targets, highlighting the need for government legislation to align the regulation and benchmarks regarding embodied carbon moving forward. The RIBA and LETI currently provide optional targets for the reduction required in embodied carbon, whilst British Standard EN 15978:2011 is in place as a standardised calculation method for measuring embodied carbon. To mainstream action beyond the few industry pioneers, leadership is required from the government, to provide clarity on how embodied carbon is to be regulated with clear benchmarks and targets. If we are to gain a true understanding of our carbon output as we move towards the 2030/2050 targets of becoming decarbonised and net zero, it is critical that embodied carbon is regulated for all construction projects.


May 2021



[2] ACAN (2021) ‘The Carbon Footprint of Construction’ Link

[3] Marin County, California (2019) “Low Carbon Concrete Requirements”

[4] Platform CB’23

[5]  Sturgis Carbon Profiling / RICS

[6] California (2017) “Buy Clean California Act” Link


[8] Los Angeles Metropolitan Transportation Authority (2007) “Construction and Demolition Debris Recycling and Reuse Policy”