Industry support for the regulation of embodied carbon

abrdn Investments

“abrdn Investments are supportive of the regulation of embodied carbon. We have already made commitments that include reducing the embodied carbon in our real estate funds, and we believe that the requirements to report whole life carbon, and set informed limits on embodied carbon, would help the real estate sector to decarbonise.”

Dan Grandage

Head of ESG, Private Markets

NatWest

“NatWest supports the proposal of regulating embodied carbon and we see this as a vital step towards decarbonising the built environment and achieving net zero by 2050. Regulation is one of the key mechanisms that drive sustainable behaviour and action amongst investors, tenants, developers and home owners. As an organisation we have reduced emissions in our own operations by 46% against a 2019 baseline and are working towards being climate positive by 2025. NatWest has committed to providing £100bn of climate and sustainable finance by the end of 2025 and halving its financed emissions by 2025.”

Marcos Navarro

Director & Sustainability Lead

JLL

“JLL supports amendments to Building Regulations requiring assessment of whole life carbon emissions and limitation of embodied carbon emissions. We recognise that, to have a legitimate net zero carbon strategy, companies need to include their embodied carbon emissions. In 2019 JLL committed to be net zero across all of UK Workplaces by 2030 and to spearheading the adoption of net zero carbon buildings across the UK. Globally our target is to achieve net zero across all of our operations globally by 2040. The regulatory changes within Part Z will ensure that the whole real estate sector adopts an inclusive approach to rapidly, and fully, decarbonize.“

Emma Hoskyn

UK Head of Sustainability

Royal London Asset Management

“Royal London Asset Management endorses the concept of regulation that mandates the reporting of – and sets limits on – embodied carbon emissions in the built environment. Such regulations are aligned with RLAM’s Property net zero carbon development ambitions, and should encourage further decarbonisation in our industry by helping to ensure everyone plays by the same ‘sustainability’ rules.”

Tim Coffin

Responsible Property Investment Manager

Barratt Developments

“We have been calculating the embodied carbon of our homes for over ten years now, and will continue to do so as part of our Science Based Targets commitments. We are also developing requirements for our supply chains to support this process through provision of Environmental Product Declarations. As such, we welcome regulation to mandate the reporting of whole life carbon, leading to the eventual introduction of embodied carbon limits in construction.”

Oliver Novakovic

Technical and Innovation Director

Urban&Civic

“Urban&Civic are fully supportive of introducing the Part Z amendment to the Building Regulations, making it a mandatory requirement to assess whole life carbon and place limits on embodied carbon emissions on construction projects. At Urban&Civic we have committed to being net zero for scope 1 and 2 emissions by 2030 and scope 3 emissions by 2040, acknowledging the significant contribution that embodied carbon makes to our scope 3 emissions. The proposed regulatory amendment would be an important step for the industry to take action and collectively help to meet society’s decarbonisation goals.”

Richard Quartermaine

Head of Sustainability

 Grosvenor Great Britain & Ireland

“For too long embodied emissions in construction have been hidden in the built environment. With today’s call the industry is asking for regulation to ensure that every significant UK development tracks and limits its full carbon footprint. We already do this for our large development projects and the time is right to introduce legislation for the whole industry.”

Tor Burrows

Executive Director, Sustainability and Innovation

Stanhope PLC

“Stanhope fully supports the principle of regulating upfront embodied carbon in construction. The impact of these emissions arising from global supply chains cannot be overstated in the critical decade of climate action ahead, and they are currently not given the same level of attention as operational energy which is embedded in current building regulations. We look forward to engaging with the government and our industry peers to develop appropriate benchmarking, regulations and guidance contributing to the UK decarbonisation process.”

Adam Smith

Sustainable Design Leader

Landsec

“Nearly 50% of whole life carbon emissions of a building occur before it is even occupied. Yet these emissions are entirely unregulated and the focus of building regulations for new buildings remains on the expected energy and carbon emitted from running the building.

Landsec has been undertaking embodied carbon assessments and driving reductions on its development activities since 2013 and fully supports these assessments becoming a legal requirement as part of Building Regulations. This is to ensure that the whole impact of a building is accounted for and we have clear and measurable ways of achieving the emissions reductions needed to get to net zero.”

Jennie Colville

Head of Sustainability

British Land

“To achieve lasting emissions reductions from the built environment, we need to develop, manage and use space more sustainably. British Land has committed to making our whole portfolio net zero carbon by 2030, setting stretching targets for embodied and operational carbon performance. We support this call for a change to building regulations to limit embodied carbon emissions and embed whole life carbon reporting across our sector.”

Matthew Webster

Head of Environmental Sustainability

Lendlease

“At the moment government only regulates operational energy used to heat, light and cool buildings. But we also know that if we look ahead to 2050, approximately 50 per cent of the carbon emissions associated with new buildings will come from the so-called embodied carbon, the carbon that goes into making the steel, the concrete and other materials that then go into our buildings, which at the moment isn’t regulated at all. Steel and concrete each account for 7 to 8 per cent of global greenhouse gas emissions, so unless we start to regulate the use of these materials in terms of the embodied carbon impact we are missing the proverbial elephant in the room.”

Paul King

Managing Director Sustainability & Social Impact - Europe

Bruntwood

“Bruntwood supports the need for embodied carbon regulation in the UK. We are already doing both operational and embodied carbon assessments on all of our new developments and major refurbishments,  so a standard methodology for reporting and limiting carbon will create a level playing field for everyone, and bring some much needed transparency across the industry.”

Chris Oglesby

CEO

Willmott Dixon

“Willmott Dixon supports the need for regulation requiring the assessment and reduction of embodied carbon. 

As we make buildings more efficient to run, embodied carbon becomes an increasingly important element of their environmental impact. We have committed to achieving net zero embodied carbon on our projects by 2040 and are already working with customers to assess and reduce embodied carbon. However, it remains a complex challenge and if we are to truly decarbonise the built environment then we need much wider industry action and collaboration.”

Michael Cross

Head of Partnerships & Innovation

Multiplex Europe

“Tackling embodied carbon is undoubtedly one of the most important challenges for everyone working in the construction sector. It represents a significant proportion of emissions generated by our industry, and reducing embodied carbon currently requires a series of voluntary decisions and actions across the value chain. Regulating embodied carbon through legislation will help shift the problem-solving from optional to mandatory, which our sector urgently needs. That’s why Multiplex Europe fully supports the incorporation of embodied carbon reduction into building regulations – and Part Z is an important start.”

Andy Butler

Technical Director

BAM Construct UK Ltd

“BAM are fully supportive of the proposal to regulate the measurement and limiting of embodied carbon via an addition to the building regulations. We are already measuring embodied carbon and working with public and private sector clients to better understand embodied impacts and how to tackle them. This is still not the norm though. The proposals would ensure that this action spreads across the entire industry and importantly, start to embed carbon thinking into every day decision making in delivering building projects.”

Jesse Putzel

Head of Sustainability

Sir Robert McAlpine

“Sir Robert McAlpine supports Part Z. Our whole industry needs to accelerate action on emissions as a matter of urgency. Part Z would be a significant step for policymakers to strengthen regulation and drive the ownership and collaboration needed to make sure we all rise to the challenge, together.”

Simon Richards

Sustainability Director

Laing O’Rourke

“At Laing O’Rourke, we have ambitious decarbonisation targets: to achieve operational net zero by 2030 and to be a net zero company before 2050. We know this will not be easy, but we are already working to reduce both the embodied and operational carbon of the buildings and infrastructure we deliver, and to develop innovations and will drive change across the sector. Reducing GHG emissions from the built environment requires urgent action from many parties, including non-industry players. That’s why we welcome Part Z – mandating the assessment and limiting of embodied carbon in buildings via the planning process would increase the entire sector’s focus on ways to accelerate and make the progress required.”

Vicky Bullivant

Group Head of Sustainability

Morgan Sindall Group

“Morgan Sindall are broadly supportive of the principles of Building Regulations Part Z to measure and limit embodied carbon. Tackling embodied carbon across the life of an asset is an important part of our commitment to be a responsible business, and we use our whole life carbon assessment tool CarboniCa to enable our customers’ low carbon aspirations. Part Z provides an opportunity to articulate a consistent approach to carbon assessment methodology, scope definition and target-setting across the sector, and should lead to year-on-year reductions in embodied carbon by encouraging greater innovation and transparency of product emissions in the supply chain. Crucial to the achievement of Part Z will be early engagement of the supply chain on projects to influence design and procurement decisions.”

Graham Edgell

Director of Sustainability & Procurement

ISG

“With the ever growing drive for net zero across the built environment, it’s paramount that we use all the tools available to us in order to capture emissions of the whole lifecycle of a building. Regulation is one of those tools.

Whilst operational energy and carbon has rightly been a focus for regulation, we have neglected a large proportion of the carbon created through the delivery of projects in the form of embodied carbon. The industry has taken some great steps towards tackling the problem of embodied carbon in the last few years, but much more is needed.

In setting regulation for the measurement and reporting of embodied carbon emissions, Part Z will help to focus our industry, create some consistency and accelerate the action needed to decarbonise the built environment. For these reasons, ISG support the addition of embodied carbon measurement, reporting and reduction to the building regulations.“

Ross Wood

Group Head of Sustainability

Mace Group

“Mace Construct fully calls to include embodied carbon assessments within the Building Regulations through a new ‘Part Z’ amendment.

As a business, we are committed to pursuing a sustainable world and as a result, we have committed to reducing client carbon by 1 million tonnes by 2026. We are achieving this both through deep retrofits but also reducing the embodied carbon of new build construction through innovative solutions such as low-carbon cassettes.

However, while the industry is already doing a lot in this area, there is an urgent need for greater uniformity in calculation methodology. Putting embodied carbon into legislation will help align the industry around a defined carbon framework thereby accelerating our sector’s decarbonisation journey.

We look forward to working with industry colleagues to help make the clear case to government for Part Z”

Andrew Mitchell

Operations Director - Sustainability

VolkerWessels UK

“Given the current climate emergency we believe it is essential that the industry respond with clear unambiguous measurement metrics allied to regulations to reduce the carbon impact of the construction industry. VolkerWessels UK wholeheartedly supports the introduction of Building Regulations - Part Z which aims to report, set limits and targets for the reduction of embodied carbon of a project.”

Adrian Shah-Cundy

Corporate Responsibility Director

Bouygues UK

“Regulations have so far only focused on the greenhouse gases emitted by buildings in operation. It is indeed paramount that they are tackled, and the industry has developed methodologies to support the necessary improvements. Embodied carbon, although of the same magnitude, has been left aside too long by regulators and undoubtedly represents one of the most important challenges the construction sector must face. As a responsible and committed business, Bouygues UK strongly supports the principles of Building Regulations Part Z to measure, report and reduce the Embodied Carbon of projects. Our collective target to become Net Zero Carbon will require our manufacturers, supply chain partners, contractors but also clients and decision makers to transparently collaborate for a better future.”

Romain Richli

Head of Environment and Sustainability

McLaughlin & Harvey

“McLaughlin and Harvey are fully supportive of the principles of an embodied carbon approach, as detailed in proposed Part Z amendment to Building Regulations. Whilst the industry remains without regulation, the inconsistency in approach to embodied carbon emissions is not conducive to the true collaborative efforts that are needed. The introduction of legislation will bring year-on-year improvement and cooperation across client, design, procurement, operational and deconstruction aspects to deliver organisational and industry net zero targets”

Carl Rushton

Head of Sustainability

Igloo

“Igloo supports the principles behind Part Z and is working to deliver them through initiatives like our Home of 2030 winning design, igloo footprint and Planet Positive Homes. Regulating UpFront carbon, in new construction and retrofit, is a critical missing element in Building Regulations and planning policy.

Part Z should be adopted as soon as possible, no later than the Future Homes Standard, and set progressive targets that are 1.5 degree aligned and that encourage natural materials. Policy will also be needed to make product specific EPD’s simpler, ubiquitous, continuously updated and electronic data based by default”

Chris Brown

Executive Chair

Urban Splash

“Rightly, there is huge focus on operational carbon within the current building regulations, and we fully support the expansion of this in the upcoming Future Homes Standard.  However, the elephant in the room is embodied carbon and this needs addressing urgently. A recent study of our own Scope 1, 2 and 3 emissions shows that our Scope 3 embodied carbon emissions are by far the largest, accounting for 94% of whole life cycle emissions 

 As UK energy supplies are decarbonised this percentage will only increase, bringing embodied carbon into even sharper focus. Reducing embodied carbon emissions is now the biggest challenge for the construction industry if it is to move to a more sustainable footing.”

Jonathan Falkingham

Co-founder & Creative Director

Thakeham Group

“As an SME housebuilder, we acknowledge the impact of the decisions we make and the impact of that on our Scope 3 emissions, and as such we fully support the call for embodied carbon to be regulated in the UK. 

In January 2021 we committed to Carbon Neutral Production by 2025 - covering A1-A5 and prioritising the areas of highest impact through substructure, superstructure and facade. We believe we should be fully informed throughout on the whole-life impact of design and specification, and that of the construction phase including transport of staff, materials, and waste. 

We will share our approach with the housebuilding industry to develop an approach that can work for all size developments and housebuilders alike.”

Josie C-Thornewill

Sustainability Director

Off Site Homes Alliance (OSHA)

“The Off Site Homes Alliance is a large client group of registered providers, fully supported by a considerable group of industry stakeholders and key influencers, all driving the use of MMC/Offsite processes, and eliminating carbon from the process as a pre-requisite. We are focussing our efforts on both operational 'and' embodied carbon and as such, will meet the targets for our aggregated assets well before the industry/global target(s). We therefore fully support the proposal for UK Building Regulations to require the assessment and limitation of embodied carbon in construction, as a necessary driver of behaviour and process, and hope that we see this essential tool sooner rather than later.”

Mike Ormesher

Project Director

Elmhurst Energy

“Elmhurst Energy supports the call for embodied carbon to be regulated in the UK. The undoubted progress that have been made to reduce the “in use” energy consumption and carbon emissions from buildings means that now is the time to consider the carbon embodied in construction. As the UK's largest independent provider of energy assessment training, software and accreditation, we have been helping energy and retrofit professionals to respond to UK energy regulation for nearly 30 years, and are now looking to support the industry in its journey to net zero by extending our services to cover competency and accreditation of embodied carbon assessors. Regulation in this area would provide both the level playing field that is needed to deliver consistent embodied carbon reductions across industry, and retain consumer confidence, so we welcome this proposal.”

Martyn Reed

Group Managing Director

Arup

“Around 10% of our national GHG emissions are associated with construction (embodied carbon). To reduce embodied carbon impacts in line with the national net-zero 2050 pathway, we need firm, supportive legislation which sets out a clear requirement to measure, report, and reduce against aligned targets.”

Chris Carroll

Net-Zero Buildings Leader, UKIMEA Region

WSP

“Operational carbon reductions in the last 20 years were generated by tightening up the appropriate building regulations in 2002 which galvanised clients, design teams and the supply chain. A similar transformation is extremely important and urgently required within the embodied carbon sphere, through a whole life carbon regulation in direct response to the climate emergency.”

Kamran Moazami

Managing Director, UK Property & Buildings

Skidmore, Owings & Merrill (SOM)

“Climate Change and it’s potential to cause lasting damage to our ecosystem's way of life is an unprecedented existential and moral challenge. As designers, SOM are key to addressing climate change, and we can improve our built environment and reduce the energy intensity of buildings we design. But we--and all designers--work within economic and social frameworks, which shape all development. It is our firm view that significant, wide-spread change is only possible if there is a strong legislative framework which mandates carbon reductions across the sector"

Dimitri Jajich

Structural Engineering Director

Atkins Limited

“Atkins support the principle of regulating embodied carbon in the construction industry. As designers, it is imperative that we are all assessing, measuring, tracking and minimising whole life carbon emissions and limiting embodied carbon emissions for all building projects. We live in challenging but exciting times with the responsibility, opportunity and desire to make significant and positive change to our environment through adopting low embodied carbon solutions and embracing new technologies. Part Z could be a key enabler for our industry to meet the UK Government's Net-Zero Carbon commitment by 2050.”

Gary Frame

Regional Director

Mott Macdonald

“Mott MacDonald fully supports the regulation of embodied carbon, ensuring all steps in the whole life-cycle are taken into consideration; from design and construction, operation and maintenance right through to de-construction. Taking a whole life approach to assess the impact of the built environment is paramount in developing solutions that are sustainable and address climate change risk.”

Sally Sudworth

Global Head of Sustainability & Climate Change

Sweco

“Operational Carbon from buildings is half the story. Without embodied carbon evaluated as part of the building regulations framework, it will not be possible to set in motion the economic demand for decarbonising building material and truly reduce net emissions from construction activities. Zero carbon operation requirement is set within the UK's building regulations. The buildings of the future are required to use a minimum or no energy to serve the internal environment; therefore, the embodied carbon is of the essence when it comes to tackling climate change. At Sweco, we have endeavoured to put embodied carbon at the heart of our design decision-making processes. Therefore we strongly support the implementation of Part Z within the UK building regulation.”

Kartik Amrania

Head of Building Sustainability

Allies & Morrison

“The embodied carbon in construction activity is one of the most direct ways in which our industry influences climate change - yet these impacts remain unregulated and unrestrained. Allies and Morrison wholly support this initiative which ensures that embodied carbon reduction is no longer an aspiration but an obligation for all.”

James Woodall

Head of Sustainability

Sheppard Robson

“Our industry must take action to recognise, report and reduce the contribution that embodied carbon makes to the built environment. This must include discouraging excessive and unnecessary use of material.

Therefore, Sheppard Robson fully supports and endorses the regulation of embodied carbon.

There has been a lot of progress in recent years to bring this subject to the forefront, driven and championed by leaders in our industry. However, achieving the consistency, integration and full supply chain upskilling required, at the speed and scale required, is only possible through ambitious and progressive legislation. We must act now.”

Ruth Marsh

Head of Sustainability

Feilden Clegg Bradley Studios

“Embodied carbon regulation is essential if we are to create a level playing field to enable the construction industry is to make its contribution to meeting our governments climate change targets over the crucial next decade. We can hope for carbon capture and a rollout of renewable energy, but any new building we build now will have released between 50 and 75% of its lifetime carbon before it is even occupied, so our focus has to be on the embodied carbon in construction. Regulation will help the industry focus on a new generation of low carbon materials”

Peter Clegg

Senior Partner

Allford Hall Monaghan Morris

“AHMM supports the principle of regulating building related embodied carbon. 

Over the last couple of years, AHMM have developed our own digital tools to help quantify, measure and interrogate embodied carbon in our developing designs. Robust, transparent and collaboratively developed limits and reporting procedures are required to help our profession, and wider industry, drive down up-front and life-cycle embodied carbon emissions.

A new Approved Document will help set the trajectory in embodied carbon emissions reductions required to address the climate emergency.”

Craig Robertson

Head of Sustainability

RSHP

“Sustainability has been one of the foundations of our practice's urban and architectural ethos. Our approach has taken different forms, evolving over time. The embodied carbon component of construction's impact on the environment has come into ever sharper focus, the urgency of taking action ever more apparent. Meeting these challenges - how and with what materials we build in future - will require innovation, resourcefulness and adaptability from the whole construction industry. For the architectural profession, this will also stimulate new ways of thinking about design and the role buildings occupy in the carbon economy.”

Stephen Barrett

Partner

UK Green Building Council (UKGBC)

“UKGBC has been advocating for regulation of embodied carbon for many years and welcomes the growing industry focus on this vital aspect of carbon reduction within the built environment. The Net-Zero Whole Life Carbon Roadmap for the Built Environment, launching at COP26, demonstrates the importance of reducing embodied carbon emissions if the industry is to become net-zero carbon by 2050.

One of its headline messages is the need for regulation of upfront embodied carbon, alongside a range of supporting policy proposals and enabling actions. We will continue to collaborate with built environment stakeholders in dialogue with policy-makers to turn these proposals into reality."

Alastair Mant

Director of Business Transformation

Construction Industry Council

“Through our Climate Change Action Plan for professional institutions, we have highlighted the need for reporting on embodied carbon. We welcome the excellent work that is being done through the Part Z initiative to drive forward the principle of embodied carbon regulation.

We need to decarbonise the built environment and transparency about emissions is an absolutely critical step if we are to take stock of the challenge for building projects at an early stage.”

Stephen Hodder MBE

Chair of the CIC Climate Change Committee

The National Building Specification (NBS)

“The NBS is supportive of making fundamental changes that will bring the focus on embodied carbon to the forefront. We are committed to continuing to make improvements to the specification technical content, allowing achievable sustainable goals to be part of the project brief and the performance requirements through the whole life cycle of a construction project. We need to help educate the construction industry and we all have a part to play if we are going to have any chance of achieving net zero.”

Phil Simpson

UK Technical Content Manager

The Institution of Civil Engineers

“The Institution of Civil Engineers wholeheartedly supports the regulation of carbon assessment and embodied carbon, as this is a necessary, achievable and urgent aspect of the transition to net zero. The Carbon Project, founded and led by the ICE, recommended an addition to building regulations that concern embodied carbon in buildings, as well as an exploration into options for the setting of carbon benchmarks and targets.”

Rachel Skinner

President

The Institution of Structural Engineers

“Because Structural Engineers are an intrinsic element in the professional design and construction team, efficient and effective deployment of materials in structural design is at the heart of reducing embodied carbon and as such,

The Institution of Structural Engineers welcomes this initiative to focus attention on appropriate Building regulation via the imaginative development of ‘Part Z’.”

Don McQuillan

President

The Royal Institute of British Architects

“Embodied carbon accounts for a large proportion of emissions produced by the built environment. As such the Government must urgently address it as part of its strategy to reach net-zero. We will continue to call on the Government to introduce regulations that stipulate consistent assessment and reporting of whole life carbon, including setting specific targets for embodied carbon.”

Alan Jones

President

Chartered Institute of Building

“Sustainability and the push to achieve net zero have, quite rightly, taken their place as priorities in construction. CIOB is supportive of regulatory moves which enable a focus on embodied carbon, not just operational carbon emissions, and add weight to its consideration as part of the construction and development process. Sustainability is already something which informs much of our work - and will for years to come - and we have been clear to our members that opportunities to take a more environment-centred approach, combined with practical measures and clarity in legislative requirements, should be welcomed. The industry needs to walk the walk on minimising climate change, not just talk the talk, and we expect CIOB members to update their knowledge through CPD and understand how they can make a meaningful positive contribution to achieving net zero.”

Caroline Gumble

Chief Executive Officer 

The Chartered Institution of Building Services Engineers

“CIBSE promote the efficient use of resources and effective, comprehensive, action on climate change. This must include both operational and embodied carbon, and there is therefore a need to regulate embodied carbon. Industry leadership in the past few years has allowed the development of methods and expertise among market leaders, which now makes it possible for regulation to happen and reach the whole sector.  MHCLG have already indicated they would look at this issue, as part of their wider work on low carbon buildings. We support this initiative which demonstrates wide industry backing and provides a starting point.”

Historic England

“Historic England supports the regulation of embodied carbon and we see this as an important step towards decarbonising the built environment, reducing the use of natural resources, eliminating unnecessary waste and achieving net zero by 2050. By avoiding needless demolition and by re-using and adapting our existing buildings appropriately, we can not only reduce carbon emissions, but also improve the quality of the built environment and nurture the skills needed for a greener economy. Historic England commits to continue providing accessible, tailored and practical guidance, training and support for those seeking to re-use historic buildings. We would welcome regulations that help ensure the consistent assessment and reporting of whole life carbon which, in turn, will lead to a more sustainable approach to development.”

Ian Morrison

Director of Policy and Evidence Policy & Evidence

The Concrete Centre

“The cement and concrete industry in the UK is committed to reducing the embodied carbon of its products and providing consistent Life Cycle Assessment data compliant with the relevant codes and standards. The Concrete Centre supports the measurement of whole life embodied carbon across construction at project level in a straightforward and consistent manner.”

Claire Ackerman

Director

The Steel Construction Institute (SCI)

“Although more needs to be done to reduce operational carbon emissions, embodied carbon also has to be measured, managed and reduced, whilst considering wider sustainability and economic drivers.

SCI therefore supports the principle of regulating embodied carbon to contribute to meeting national net-zero targets and is happy to be involved in their development, provided they are industry-led. This industry involvement is important to ensure that achievable yet ambitious carbon targets are developed within the wider context of the industry and economy, to avoid unintended consequences. As with all Approved Documents, the proposals should be subject to a regulatory impact assessment.”

Dr Michael Sansom

Associate Director, Sustainability

Timber Development UK

“Timber Development UK recognise that climate change poses a threat to the economy, nature and society-at-large, and have committed to take action to support our members in halving their greenhouse gas emissions intensity before 2030, and achieve net-zero emissions before 2050. We therefore fully support legislation that would require the assessment of whole life carbon emissions, and limiting of the embodied carbon emissions, for all major building projects in the UK.”

Charles Law

Sustainability Director

The Structural Timber Association

“The Structural Timber Association supports the idea of the regulation of embodied carbon, as a necessary requirement to support the construction industry's commitment to achieving net zero.”

Andrew Carpenter

Chief Executive

The Institute of Directors

“Embodied carbon is a huge missing link in the effort to decarbonise the property and built environment industry, as most current initiatives focus on operational carbon emissions. The Institute of Directors Property and Built Environment Group committee is fully supportive of the effort to regulate embodied carbon in the construction and property industry. As laid out in the IoD’s ‘Green Incentive’ policy paper, we support efforts to help businesses decarbonise in all industries, and we advocate setting clear decarbonisation goals, establishing a clear business case and incentives to decarbonise, providing a methodology for helping businesses to decarbonise, and ramping up resources and support for businesses, particularly SMEs, on their decarbonisation journey. Additionally, the IoD has been certifying its carbon footprint since 2019, and it plans to reduce its environmental impact each year to reach net zero.”

Richard Nelson

Chair, The Institute of Directors Property and Built Environment Group

The London Energy Transformation Initiative (LETI)

“LETI very much supports the principle of regulating construction embodied carbon as a key component of our route to zero carbon, in its place alongside operation energy. Low embodied carbon is an imperative that has few market drivers and requires that clear regulatory level playing field to progress. The key elements of measurement, reducing, verifying and sharing, allow industry to respond positively and rapidly to play its part.”

Chris Twinn

University College of Estate Management

“It is vitally important to understand the whole picture of how carbon is used and assessed in buildings, and in particular how reductions in embodied carbon will help to meet net zero targets”

Aled Williams

Executive Director (Research, Innovation & Partnerships)

The Royal Town Planning Institute

"The RTPI has been calling for use of our existing built up areas - including town and city centres - in preference to green fields where possible and we are now coming to appreciate the value of reusing rather than demolishing buildings. We join this call for more measurement of embodied carbon and its use in regulation and policy.”

Victoria Hills

Chief Executive

Robert Bird Group

“The building industry as one of the biggest contributors to planetary breakdown requires regulation together with independent enforcement to ensure global warming emissions are reduced across every project in the industry. I believe documents such as Part Z are necessary in achieving more drastic regulatory adjustments.
As a sustainability leader in my business nationally within Australia and globally connected I’m keen to keep abreast and support new regulation and efforts to centre the industry on the climate emergency.”

Ed Bond

Principal

Buro Happold

“As an international business responsible for the design of buildings and infrastructure in the UK, we have committed to halving the embodied carbon in our projects by 2030. A change in building regulations is essential to recognise the importance of measuring and reducing the embodied carbon in building design. We support wholeheartedly the proposals for UK Building Regulations to mandate the assessment and limitation of embodied carbon in construction. This would be consistent with the UK’s declared commitment to achieve Net-Zero Carbon by 2050.”

Dr Sarah Prichard

Partner & UK Managing Director

Hopkins Architects

“Hopkins Architects fully agrees that the Building Regulations should be expanded to regulate and limit embodied carbon emissions as part of the urgent need to respond to Climate Change. Similar regulation already exists in other countries, and it is important we take action too. Such a move would help align the UK construction industry in tackling the main source of our buildings’ lifetime emissions. 

Our hope is that this proposal galvanises the Government to act on this with urgency, and we welcome the opportunity to shape this important regulation.”

Mike Taylor

Principal

White Arkitekter

“White Arkitekter fully supports this initiative. Our strategic plan for climate neutral development necessitates dramatic reductions in embodied carbon as key to our collective vision to deliver regenerative architecture. Regulating the measurement and assessment of embodied carbon will provide the framework that our industry needs to decarbonise. We’ve seen how stringent regulations can coerce industries towards a green transition - notably the ban on freon that was depleting our ozone layer. Part Z provides a pathway for the UK to accelerate reductions in embodied emissions in construction and drive innovation across our sector. Including, materials science and circularity, retrofit, low-carbon methods of construction and timber construction. We have to work together on global, national and local levels and we will continue to share our learnings from Scandinavia.”

Carl Backstrand

Partner & Deputy CEO

Expedition Engineering

“That Whole Life Carbon will become as important as gravity, fire safety, equality of access, price and aesthetics makes the new Building Regs Part Z one of the most important pieces of legislation the UK could enact in our lifetimes. A few modestly worded clauses populate the void with performance data for everyone to learn from, while setting up a lifelong carbon reduction challenge…and in the process will upend the way designers and clients look at buildings, making “forever” a little more likely. A masterly initiative and one we at Expedition completely support.”

Chris Wise RDI

Senior Director

Waugh Thistleton Architects

“The construction industry has been tinkering around the edges for decades, the time for serious reform is upon us - accounting and challenging the embodied carbon of construction will encourage meaningful transformation. Resource conscious decisions need to be at the forefront of design; such as whether to retain existing buildings and do we really need that cantilever.. or even that basement? The sooner embodied carbon is regulated, the better.”

Andrew Waugh

Founder

Perkins & Will

“The proposed Part Z of the Building Regulations fills a critical gap by mandating the assessment and limitation of carbon emissions embodied in the construction of buildings. Embodied carbon has become hugely significant as a proportion of total building related emissions as operational carbon emissions have been progressively reduced through Part L of the Building Regulations. These proposals are a necessary step to achieve UK’s sixth carbon budget set by the Climate Change Committee. The document not only provides a framework to set better carbon targets but also to increase carbon literacy within the construction industry.”

Asif Din

Sustainability Director

Bennetts Associates

“We now know that the construction of buildings has a significant carbon impact, often greater than the operational impact that is regulated. There is an increasing amount of voluntary action that is taking place, but in order to achieve the step change in attitude required across the whole industry requires regulation that mandates the assessment and limiting of embodied carbon. Bennetts Associates strongly supports this proposal”

Peter Fisher

Director

Levitt Bernstein

“Levitt Bernstein believe that change is feasible today and not tomorrow. Building regulations could drive embodied carbon to the forefront of the design, specification and construction process. We welcome the proposed amendment to the building regulations that will mandate the assessment and limiting of embodied carbon.”

Zoe Watson

Sustainability Specialist

Cundall

“Cundall wholeheartedly support the regulation of whole life carbon including both embodied and operational energy and are working with local and national Government, professional bodies and industry groups to development these standards. The Government must be ambitious and decisive with these targets in order to meet their net zero carbon commitments – ‘Part Z’ would be a good start.”

Simon Wyatt

Sustainability Partner

AESG

“AESG fully support the proposal for UK Building Regulations to require the assessment and limitation of embodied carbon in construction as a necessity for meeting the reduction targets set out within the UK carbon budgets. We have the technology and capability to reduce the embodied carbon within our buildings but lack the legislative drivers necessary to bring about universal change. We therefore welcome the proposed Part Z amendment to fill a critical gap in mandating the assessment and limitation of embodied carbon.”

Phillipa Grant

Global Director of Sustainability

Goss Structural Ltd

“As a small structural consultancy specialising in the domestic construction sector we deal with a high volume of small projects. These all require steel, concrete, masonry and timber. Any tool that can support and empower us to reduce the amount of carbon intensive materials that we specify on projects will be extremely well received!”

Tom Goss

Director

RPS Group PLC

“At RPS, we support the industry call for regulation of embodied carbon in construction. Great strides have been made as a result of regulation of operational energy related emissions and our focus now needs to be on embodied carbon. We have the will and the know how to do this, but we need the Government to follow up its Net Zero ambitions with consistent policies. Reducing carbon, reduces cost so this is a win win for clients too.”

Jen Hamilton

Managing Director Design

Civic Engineers

“This is a great piece of work. It is really important that methods of embodied carbon counting are standardised and even more important that ambitious limits are set on development to encourage use of more sustainable options and help us mitigate the impacts of climate change.”

Robert Westcott

Director

Hawkins\Brown

“Hawkins\Brown are advocates of a phased approach to Embodied Carbon regulation. While the industry has spent decades reducing operational carbon and eliminating the use of fossil fuels, we are still a long way from reporting embodied carbon on every project. The only way of doing this at the speed and scale which is required is to legislate measurement, ensure consistency, set benchmarks and eventually mandate limits.”

Louisa Bowles

Partner & Sustainability Lead

BakerHicks

“BakerHicks wholeheartedly support the proposed Part Z changes to the Building Regulations. As designers it is important that we lead the way in setting sustainable practices, use less energy in all our projects and help create the environment our society needs. There is already a real appetite for more environmentally friendly buildings, but it is far from standard practice. To achieve this regulatory change is essential, and we believe Part Z will be the catalyst that accelerates the drive for decarbonisation our industry needs.”

Alwyn Hanekom

Managing Director, Infrastructure & Sustainability Advisor

Hydrock Consultants Ltd

“Hydrock fully supports the regulation of embodied carbon through the proposed Part Z assessment process. A clear trajectory for operational emissions is already in place and by understanding and reporting on the embodied carbon use within buildings, it will allow targets to be set and driven towards to reach a true net zero carbon built environment by 2050. With the increased uptake of Whole Life Carbon by the GLA and other local authorities, regulation within the construction industry will improve our standards of reporting and allow accurate comparisons between buildings and assets.”

Josh Bullard

Division Director - Smart Energy & Sustainability

Heyne Tillett Steel

“It is clear how much we need to limit embodied carbon in construction if we’re to have any chance of meeting global climate targets. The industry needs strict regulation to be capable of mitigating current carbon emissions; the introduction of a Part Z amendment to the building regulations would be a very welcome step forward”

Tom Steel

Director

Elliott Wood

“Elliott Wood agrees that ambitious change is needed to UK Building Regulations that will mandate assessments and limitation of embodied carbon in construction. There are already tools - such as The Structural Carbon Tool we developed with IStructE - that are available to help design teams estimate embodied carbon and make better decisions during the design phase.

Our industry is willing and able to make the changes needed to comply with whole life carbon regulation, and this is a clear opportunity for the Government to enact legislation that will help make that a reality. We look forward to collaborating with our industry peers to push for this much needed reform.”

Gary Elliott

Co-founder & Chief Executive

Thornton Tomasetti

“Thornton Tomasetti believe that regulation of whole-life carbon is imperative for the UK to realise its net-zero ambitions. Whole-life carbon measurement and reduction in the building industry today are required only by localised regulations and pioneering organisations. Introduction of nationwide regulations will elevate building carbon reduction to become a necessity on all projects.”

Phil Thompson

Regional Leader & Director European Operations

FMDC Ltd

“FMDC fully supports the principle of regulating embodied carbon in the construction industry. As we move towards Net Zero (Whole Life) Carbon buildings, it is vital that we properly assess embodied carbon, which accounts for an ever increasing proportion of the whole life carbon of a building. With façades encompassing a wide range of materials and accounting for up to 20% of the upfront embodied carbon of a building, façades must be made more efficient not only from an energy perspective, but also from a materials one. Clear legislation would help set the required limits and encourage the specification of lower carbon materials, as well as reuse and recycling practices.”

Simon Webster

Director

dRMM Architects

“dRMM have long championed low embodied carbon design and we have been actively involved in developing voluntary industry guidance for measuring and reducing embodied and whole life carbon. Our industry already has the tools and frameworks to measure and reduce its impact in the face of the climate crisis, and these need to be adopted as quickly and as widespread as possible. We are supportive of the introduction of regulation for assessment and reduction of embodied carbon to ensure that decarbonisation of construction becomes mandated rather than voluntary. We hope the introduction of a Part Z will help to ensure the built environment decarbonises at the pace necessary.”

Kat Scott

Sustainability & Regenerative Design Manager

Baily Garner

“Working mainly in residential housing the focus is currently on the future homes standard and retrofitting the existing stock but in a climate and ecological emergency we need to look also beyond the immediate and consider the next biggest issue and start to understand it ,measure it and act upon it sooner rather than later. Part Z is a crucial part of the adoption of whole life carbon principles and we fully support it.”

John Milner

Partner

Haworth Tompkins

“The current global climate breakdown and biodiversity loss are both closely linked with carbon emissions arising from construction materials and processes. As founding signatories of the Architects Declare movement Haworth Tompkins wholly support the initiative to bring whole life carbon to the heart of the design process by mandating the assessment and limitation of embodied carbon.”

Diana Dina

Head of Sustainability & Regenerative Design

tp bennett LLP

“Embodied carbon is at least half the problem (and therefore half of the solution) in the built environment's contribution to climate change, harmful air quality and land & water degradation. Not regulating the social and environmental impact of building materials is one of the greatest's loopholes in our sector.”

Christopher Webb

Head of Sustainability

Atelier Ten

“Atelier Ten supports Part Z regulation which is an opportunity for the UK to join the Netherlands, France and Nordic countries that have already adopted a whole lifecycle approach in their building regulations. To maintain sustainable construction, we need to act quickly to reduce embodied carbon where we can. We believe that an embodied carbon label for buildings would promote the use of sustainable materials and strategies and bring a much-needed transparency to the field, which can drive the competition, innovation, and transformation of our industry to absolute zero carbon. We have been working with the industry for years to develop the necessary knowledge and evidence base and prove its effectiveness in practice. Now it is time to bring this approach into mainstream and apply to all buildings.”

Ivan Jovanovic

Sustainability & Environmental Design Lead

Max Fordham LLP

"Max Fordham are strongly in favour of incorporating embodied carbon limits into the building regulations for new build and major refurbishments. Under current regulation, design and building practices the embodied CO2 emissions associated with constructing a building are vast, typically 5 times more than the CO2 emissions associated with running a low energy building for 50 years. This has to change if the UK is to address the climate change crisis and meet the urgent need to achieve net zero carbon emissions. Incorporating embodied carbon limits into building regulations can yield carbon reduction benefits in several ways including

a) designers will need use materials more efficiently,

b) designers will need to favour the use of low embodied carbon materials, and

c) material manufacturers will need to accelerate the decarbonisation of their processes."

David Lindsey

Senior Partner

Black & White Engineering

“A key driver towards low energy and low carbon buildings in the UK is through building regulations. Without Part L and planning policy pushing for better buildings it is likely that a large majority of the building stock would be much less efficient and emit more carbon. A building's embodied carbon can often outstrip operational carbon by orders of magnitude but it is not typically assessed unless mandated through BREEAM or GLA planning requirements. Outcomes will vary significantly depending on where the building is located due to variations in local planning policy. By producing a national document a minimum standard can be set for embodied carbon to ensure that this is being assessed and efforts are made to reduce a building's whole life carbon emissions.”

Scott Wilson

UK Head of Sustainability

Walsh

“At Walsh we recognise that the embodied carbon produced by the construction industry cannot be ignored if we are to meet the national NZC-2050 commitment.

We already monitor the embodied carbon of our designs at multiple RIBA stages, but we fully support the regulation of these assessments as part of Building Regulations. Engineers live to solve problems, and surely this is one where we can rise to the challenge!”

Seetal Pankhania

Sustainability Lead

Price & Myers

“Significant reductions in embodied carbon in buildings is a vital component in achieving nett zero in construction. A consistent, reliable and verifiable approach to embodied carbon assessment is needed to avoid mis-reporting and facilitate regulatory limits. The introduction of Part Z, used alongside Part L should finally give a framework for achieving truly low and zero carbon buildings. Price & Myers wholeheartedly support this initiative.”

Ian Flewitt

Partner

Hoare Lea

“At Hoare Lea we support this initiative to regulate embodied carbon emissions through the building regulations, across all UK nations. We have been helping leading clients act on these impacts for a number of years, however we recognise all development should be considering embodied carbon, not just the leading lights.

In a time of climate emergency, we currently have no country-wide legislation requiring these emissions to be measured, never mind reduced. In this regard we are increasingly out of step with our European neighbours.

Acting on this is an essential step in getting the UK to Net Zero Carbon by 2050.”

Ashley Bateson

Head of Sustainability

Arcadis

“The lack of regulation for embodied carbon emissions is one of the biggest gaps in a coherent strategy to decarbonise the built environment and construction. Time is now the crucial factor in addressing the climate change emergency, consequently regulatory sticks are now required to ensure appropriate action is taken. The Part Z proposal provides government with an “oven-ready” solution to introduce regulation to address whole-life carbon in the built environment and limit embodied emissions. Arcadis supports the Part Z proposal and encourages the UK Government to introduce this step change as soon as possible.”

Ben Harris

UK Climate Change & Sustainability Director

BDP

“We welcome the efforts made to regulate performance and to standardise the approach to evaluating embodied carbon impacts in the built environment. Requiring designers, funders and end-users to consider the value of materials is critical in tackling the climate and biodiversity emergency and our dwindling natural resources. Setting this baseline will also serve to furnish the industry with greater intelligence, which is necessary to incentivise progress and drive speed of change!”

Philip Gray

Head of Sustainability

WilkinsonEyre

“WilkinsonEyre support and welcome these proposals, that will unite architects, developers and contractors in the delivery of sustainable construction from conception to completion and beyond. We need legislation to bring the industry together and drive meaningful change across the whole built environment; to regulate the calculation, assessment and reduction of embodied carbon. These proposals would have the power to compel genuine industry change, align with the ambitious carbon targets already set out, and reward innovation in the field.”

Ayman El Hibri & Melissa Clinch

Sustainability Design Leads

Ramboll

"Ramboll fully supports the proposal to regulate embodied carbon and provide a consistent approach to embodied carbon assessments. While we must continue our efforts to reduce operational carbon, it is imperative that we are also minimising whole life carbon emissions associated with materials and construction processes. Addressing these sources of carbon will be critical in meeting the UK’s 2050 target. A clear legislative framework is required and Part Z is an essential step.”

Philippa Spence

Managing Director

Stanton Williams

“As one of the founding signatories of UK Architects Declare and a certified Carbon Neutral Plus organisation, Stanton Williams is committed to minimising the environmental impact and carbon footprint connected to our projects and our activities. To ensure the whole life carbon impact of construction is considered in its entirety, it is paramount that embodied carbon is regulated by mandating the assessment and limitation of embodied carbon. Part Z is a positive step change to help accelerate climate action within the built environment.”

Eleni Makri

Associate Director

Ridge and Partners LLP

“Ridge and Partners LLP recognises the importance of regulating embodied carbon emissions and the adoption of a whole life cycle approach. Over the past few years we have supported a large number of project teams to measure, quantify and most importantly understand the impacts arising from their designs and we believe that the industry is now ready to make a step forward and demonstrate compliance with the proposed regulations. It is a necessary and much needed step to support the government’s Net Zero aspirations. We believe Part Z can and will provide the legislative framework to facilitate this.”

Nick Hayes

Sustainability - Partner

B&K Structures Ltd

“B&K Structures supports the principles of Part Z – to measure and reduce the embodied carbon of buildings. We are able to assist others in the building industry by understanding our own emissions and those in our supply chain. We will continue to support the use and availability of accurate and up to date information for those calculating embodied carbon.”

Andrew Goodwin

Managing Director

Stora Enso

“Mitigating climate change requires a collaborative and science-based change in the UK construction industry. The proposed addition of whole life carbon assessments and embodied carbon limit values to the UK Approved Documents is a crucial enabler for the buildings sector to reach its net zero targets. Ultimately, all buildings must be transformed from carbon sources to carbon sinks.

Building on our long history of replacing fossil-based materials with renewable solutions, Stora Enso is proud to be working with key partners to deliver carbon-storing buildings across the UK. A scientifically proven way to use buildings as carbon storage is to capture as much embodied carbon in the superstructure as possible, easily achieved when building with cross laminated timber (CLT). Still, the buildings sector needs to transform more quickly and at greater scale from business-as-usual methods to carbon-capturing Modern Methods of Construction (MMC) for it to make a strong contribution to the UK’s binding net zero targets.

As Europe’s largest wood products supplier, Stora Enso fully supports Part Z as a key step in decarbonising the built environment.”

Johanna Pirinen

Senior Vice President Head of Sustainability, Wood Products Division

Greencore Construction

“Greencore Construction fully supports the proposal to regulate the measurement of embodied carbon in construction projects. The information obtained from these assessments will create more transparency and will encourage investors, developers, local authorities and other stakeholders to move towards low carbon construction techniques as they seek to limit their emissions. This should create financial incentives for innovation and change across the construction sector, and drive down carbon emissions.”

Martin Pike

Chairman

Buckley Gray Yeoman

“Buckley Gray Yeoman fully supports this call to fill the gap within the building regulations, ensuring that embodied carbon emissions are measured, reported and reduced for all significant developments.

Embodied carbon accounts for 10% of our national emissions and is currently unregulated at a national level. These proposals would level the playing field and ensure that the emissions caused by construction, maintenance and demolition are considered by all.

As designers we know how to reduce embodied carbon emissions, with supporting legislation we can make these reductions a reality across all our projects.”

Rachael Owens

Head of Sustainability