Planning and climate change guidance: research report issue 3

6 Emerging Approaches and Standards

6.1 introduction

6.1.1. There are several emerging approaches to dealing with whole life carbon in developments. Some of these have been driven by regulators and others have been driven by proposals from the industry itself, representing the need for consistency in approach to measuring whole life carbon of the built environment. This section summarises three proposals from the industry that are being considered and highlights associated benefits and constraints, as well as three reports from Zero Waste Scotland relating to embodied carbon in the built environment.

6.2 Proposed Amendment to the Building Regulations – ‘Part Z’

6.2.1. In 2022/23, key stakeholders within the construction industry proposed the Building Regulations amendment ‘Part Z’^[31] to the UK Parliament which outlines an industry-driven amendment to specifically address the whole life carbon of developments. Proposed Document Z outlines requirements for the assessment of whole life carbon emissions, and for the reduction of embodied carbon emissions, for all major developments.

6.2.2. Aligned with the RICS Professional Statement ‘Whole Life Carbon Assessment for the Built Environment’, and with guidance and recommendations made by the various relevant professional bodies, the proposal could ensure to the necessary focus on the built environment’s contribution to the Net Zero transition.

6.2.3. Updated in 2024, the proposal includes thresholds and would apply to developments exceeding 1000m² or involving the creation of more than 10 dwellings in alignment with the proposed size limit in the Future Homes Standard^[32]. Whilst the Future Homes Standard is UK based, SG has committed to introducing legislation by 2024 to deliver a Scottish equivalent^[33] and the thresholds proposed in Part Z could apply to Scotland as well as the rest of the UK.

6.2.4. The intention behind this amendment is to normalise whole life carbon assessments within the building design process through requirements for carbon assessment to be enforced for various building types over the next few years. This gives a period during which robust carbon limits can be determined. The proposed Part Z (2) seeks to discourage excessive resource use by setting reasonable standards for upfront embodied carbon intensity and aims to empower design teams to identify opportunities to reduce a building’s overall carbon impact.

6.2.5. Demonstrating compliance involves meeting specific criteria, including conducting a Whole Life Carbon assessment and limiting upfront embodied carbon. The implementation details cover the methodology, scope, timing, and reporting requirements for Whole Life Carbon assessments.

6.2.6. The proposal outlines upfront embodied carbon limits for different building typologies. These limits are expected to be periodically updated based on data collected through the government portal, reflecting evolving benchmarks and standards.

6.2.7. This industry-driven proposal reflects a proactive approach to address whole life carbon concerns in the building industry. By providing appropriate guidelines and standards, it aims to contribute to the built environment’s essential contribution to the Net Zero transition.

6.3 Net Zero Carbon Building Standard

6.3.1. The Net Zero Carbon Buildings Standard, the UK’s first cross-industry and science-based carbon standard, is due to be published in Q2 of 2024^[34]. Developed by leading organisations with a relevance to the built environment, the Standard can be applied in Scotland and the UK and will set out metrics by which net zero carbon performance is evaluated in a single agreed methodology. It will incorporate performance targets and limits that have been derived from an analysis of the UK’s Sixth Carbon Budget, in line with a 1.5°C trajectory, and from data gathered across different sectors within the built environment.

6.3.2. The Standard is for anyone involved in the development process through from investment and design to contractors and developers, as well as suppliers and manufacturers. It is also aimed at those who wish to be involved with any aspect of developing a ‘Net Zero Carbon Building’ or demonstrate that their building is Net Zero Carbon (NZC) in accordance with an industry-agreed standard.

6.3.3. Two key principles for the Standard are that it should be stretching but achievable, and that it should be science-based. To reconcile these aims, two workstreams have been established to develop appropriate NZC limits. The bottom-up workstream will use benchmarking, case studies, and modelling to understand levels of performance. The top-down workstream will establish the relevant national carbon budgets which show what the industry needs to achieve to play its part in a NZC UK. The outputs from these workstreams will then be combined to create NZC limits and targets for various building types.

6.3.4. Therefore, the Standard aims to provide a clear and consistent methodology that will enable industry to robustly prove that their built assets are Net Zero Carbon in line with the UK’s climate targets and a 1.5°C trajectory.

6.4 Climate Emergency Response Group – Net Zero Test

6.4.1. NPF4 Policy 2 ensures that developments and projects are in line with net zero and appropriately address the climate crisis. In August of 2023, the Climate Emergency Response Group (CERG) released briefing papers detailing proposals for immediate action on four priority issues to deliver the required action to address the climate emergency in Scotland^[35]. A group of leaders from Scotland’s private and public sector as well as delivery organisations and membership bodies, the group aims to inform and influence the Scottish Government’s response to the climate emergency by providing practical advice and solutions that can be implemented now. One of the four priorities in the 2023 briefing papers was the introduction of a mandatory ‘net zero test’ to inform all policy and investment decisions.

6.4.2. The paper details the proposed introduction of a consistent carbon assessment process for all capital projects and programmes with clear accountability procedures through the following core mechanisms:

• Screening: A qualitative screening approach would be applied to determine whether the project/policy has a positive or negative carbon emissions impact. This then informs the next stage for quantitative assessments in a tiered approach, e.g. if the projects are not aligned with a net zero trajectory, then they would be examined further under the next mechanisms.
• Detailed assessment: A detailed and quantitative carbon assessment would be applied to the relevant capital projects, policy assessments, or major investment programmes to determine quantitative emissions modelling.
• Guidance and governance: Steps to ensure transparency and effective reporting and monitoring would be carried out including the publication of the screening and carbon emissions assessment. The governance roles of appropriate checkers and owners are also outlined to ensure a robust process.

6.4.3. In the paper, CERG notes that several organisations including the UK Climate Change Commission and the Institute for Government have already called for a net zero test to ensure that all government decisions are compatible with meeting carbon budgets and, ultimately, net zero. Additionally, CERG notes that net zero tests have been adopted by other jurisdictions including New Zealand and France and encourages taking learnings from these to inform the approach in Scotland.

6.4.4. The CERG notes several opportunities that would arise from the introduction of a net zero test:

• Developing a consistent approach to carbon assessment by; building on carbon assessment approaches and guidance already in use by the Scottish Government; aligning with the UK treasury Green Book guidance to quantify whole life carbon emissions and consider the cost of carbon in the economic analysis; and supporting the adoption and integration of existing best practice standards such as PAS 2080.
• Informing policy decisions by; supporting delivery of NPF4 and associated climate policy priorities with the need for quantitative carbon assessments by providing a mechanism to integrate and deliver the policies; supporting future Climate Change Plan commitments such as more quantitative account view of how policies contribute to sectoral emissions; forming part of an effective governance framework to support the implantation of a Climate Change Plan; and supporting the government’s commitment to ensure public sector spending delivers wide benefits including a net zero transition.
• Informing spending decisions by; supporting the implementation of the SG’s commitment to further develop the carbon assessment approach for the next Infrastructure Investment Plan^[36]; and evidencing carbon cost management and the “value for money” of climate policies and programmes.
• Flagging climate risks and just transition opportunities by; signposting projects that would benefit from further consideration in terms of futureproofing for climate impacts and securing a just transition.

6.4.5. CERG suggests that the introduction of a net zero test early in the planning process to input into business case development will help to inform decisions ahead of the procurement stage, at which best-practice standards such as PAS 2080 can be applied. Thus ensuring that appropriate consideration to carbon management is seen across the project life cycle. The CERG believes that measurable action against this proposal is essential to both meet the national climate targets and give businesses, investors, and citizens the clarity they need.

6.4.6. Whilst CERG have referred to a ‘test’, this is essentially an assessment mechanism to ensure a project’s alignment to net zero. This could be in the form of a whole life carbon assessment aligned with NPF4 Policy 2a).

6.5 Zero Waste Scotland Reports

6.5.1. In recent years, Zero Waste Scotland has developed several reports discussing the relationship between the built environment and embodied carbon^[37]. Two of these reports are explored below.

Embodied Carbon in the UK

6.5.2. The report ‘Embodied Carbon: Status Quo and Suggested Routemap’^[38] is a state-of-play assessment allowing Zero Waste Scotland to explore and understand the current state of embodied carbon and the direction of travel for the construction industry. The report provides context on embodied carbon including metrics, assessment tools, data gaps and mitigation options, and provides a view on industry perspectives. It also includes a roadmap with actions for Zero Waste Scotland to accelerate progress towards managing and reducing embodied carbon.

6.5.3. The report recognises the significance of embodied carbon emissions in the built environment and highlights the need for appropriate regulation, which is further explored in the second report as outlined below. Additionally, the report details action in the absence of regulation such as Zero Waste Scotland’s involvement in developing the ‘Net Zero Public Sector Building Standard’ which is discussed in Section 5 of this report.

Regulating Embodied Carbon in Scotland

6.5.4. Zero Waste Scotland published the report ‘Regulating Embodied Carbon in Scotland’s Buildings’^[39] in 2022, highlighting the significance of embodied carbon in the built environment and discusses regulation initiatives from around the world to inform lessons for the development of associated regulation in Scotland.

6.5.5. The report discusses the increasing significance of embodied carbon emissions of buildings, stating that emissions from the Scottish construction sector (a major proportion of the building’s whole life carbon emissions) have amounted to between “4 and 5MtCO2e per year” which is reported to be around 10% of the annual quantity of Scotland’s total carbon emissions. Due to this significance, and without action, these construction-related emissions would take an increasing share of Scotland’s carbon budget.

6.5.6. The report then discusses opportunities for regulating embodied carbon in Scotland, primarily suggesting it would be likely to be regulated through building regulations which already regulate operational carbon emissions. Zero Waste Scotland suggests that a mandatory embodied or whole life carbon assessment could be included into Section 7 of the Building Standards, and this would align with other jurisdictions’ approach to regulating whole life carbon (for example as seen in Europe, further discussed in Section 7 of this report).

6.5.7. Zero Waste Scotland reference relevant initiatives and policy development such as the Net Zero Public Sector Buildings Standard and the City Region and Growth Deals, explored in Section 5 of this report. They also reference the Climate Change Committee’s 2021 recommendation to the Scottish Government^[40] to move towards minimum whole life carbon standards for all buildings, advising that a plan is needed “for phasing in mandatory whole life reporting following by minimum whole life standards for all buildings, roads, and infrastructure by 2025”.

6.5.8. Additionally, it references the Scotland’s Climate Assembly’s 2021 recommendations for action^[41] which include the implementation of “clear and future-proofed quality standards for assessing the carbon impacts of all buildings public and private using EnerPhit/Passivhaus standards (as a minimum) and integrating whole life carbon costs, environmental impact and operational carbon emissions”.

6.5.9. The report discusses UK based guidance and approaches such as LETI, RIBA, RICs, and also discusses the industry led proposal Part Z both explored in Sections 4 and 6 of this report. It also explores the international landscape, referencing European directives and initiatives as seen in jurisdictions such as Finland, Denmark, and Sweden. These are discussed in Section 7 of this report.

6.5.10. The report then explores opportunities for regulation in Scotland. It discusses important questions to be addressed such as what, when, and how to regulate, including the need to include thresholds and parameters for significance. It also provides a routemap to regulation including milestones of when to report whole life carbon emissions and the imposition of thresholds and limits. It should be noted that this routemap is less ambitious than other emerging approaches such as the industry proposed Part Z and the CERG net zero test. Given NPF4 has been in place since 2023, the proposed NPF4: Planning and Climate Change Guidance will enable a welcome acceleration to managing whole life carbon in the planning process.