Incorporating whole life-cycle greenhouse gas emissions into the Scottish Building Standards

Built Environment Forum Scotland are signatories of an open letter to Kevin Stewart, Minister for Local Government, Housing and Planning, regarding the introduction of minimum standards for whole lifecycle greenhouse gas emissions for new buildings under Section 6 of the Scottish Building Standards.

Open letter to Kevin Stewart, Minister for Local Government, Housing and Planning, the Scottish Government

Dear Mr Stewart,

We, the undersigned, are writing to call upon the Scottish Government to introduce minimum standards for whole lifecycle greenhouse gas emissions for new buildings under Section 6 of the Scottish Building Standards.

We note that the new Building Standards are due to be introduced in October 2021, with changes published one year in advance and, given the wealth of expertise in this field available to the Scottish Government, we do not see the time available to draft the necessary changes as at all prohibitive.

We further note the findings of the recent report by AECOM for the Committee on Climate Change on incorporating targets for embodied and sequestered carbon into the building standards framework, which concludes that mandatory regulation is more likely to be effective for addressing life-cycle emissions and sets out a number of options for achieving this, dependent on the level of ambition for such targets. We also note the findings of the Committee’s recent ‘Net Zero’ report, which serve to highlight the urgency of reducing greenhouse gas emissions across all sectors of the economy. And we note the conclusions of the recent report on energy efficiency to Westminster’s Business, Energy and Industrial Strategy Committee, which found that the Government is off-track to meet its targets, that policy gaps exist, and that the UK’s building stock remains one of the most inefficient in Europe [3].

In addition to reducing Scotland’s greenhouse gas emissions, regulating to reduce the lifecycle emissions of new buildings by accounting for those embodied and sequestered in materials has significant potential to leverage co-benefits to Scotland’s environment, society and economy. These include supporting the development of local, sustainable, supply chains, and associated skilled employment opportunities, and encouraging forestry and land management practices that support biodiversity and create new opportunities for recreation and tourism. This evidence has been highlighted in numerous publications, including a 2017 report for the Scottish Government by Aether UK and Glasgow Caledonian University. Glasgow is also home to the Materials Library, a unique physical and online resource managed by Architecture and Design Scotland, and harnessing this wealth of evidence and expertise would be invaluable for enabling the introduction of such standards and associated guidance [5].

Therefore, we call upon the Scottish Government to commit to introducing standards for whole lifecycle emissions under the current revision of the Scottish Building Standards. We also recommend that, in order to facilitate this within the time available, the Scottish Government should convene a short life working group on whole lifecycle emissions from new buildings. This would establish the level of ambition achievable in the lifetime of the new standards, and agree how accounting for lifecycle emissions should be incorporated into Section 6 in a manner that will facilitate the tightening of these regulations under future revisions. It would also allow the findings of the group to be completed and put out for consultation in time for the publication of the new draft standards circa October 2020.

Organisational supporters:

Common Weal

The Energy Poverty Research Initiative

Glasgow Caledonian University

Built Environment Forum Scotland

If you wish to be a signatory of this letter contact Dr Keith Baker on Keith.Baker@gcu.ac.uk.

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