As buildings account for 36% of the European Union’s CO2 emissions, reducing the environmental impact of any new building is essential to contributing to the EU’s ambition to be the first climate neutral continent by 2050.
Vincent Briard is Group Sustainability Director at Knauf Insulation. Yosr Melki is Marketing & Communications Director Western Europe at Knauf Insulation.
Any assessment of a building’s sustainability must take into account the carbon emitted from heating and cooling during the entire lifecycle of that building as well as the CO2 associated with all its components, using an independent and scientifically robust audit known as a Lifecycle Assessment or LCA.
That means examining the embodied carbon of all building materials during their lifecycle — from the extraction of materials, transportation, storage and manufacture to distribution, installation and end of life, while also looking into the operational carbon of that building resulting from its energy consumption.
Harmonised approach to assessing carbon
But to ensure everyone understands exactly what is meant by a building’s environmental impact across its lifecycle, it is essential that everyone — wherever they are based in the European Union — uses the same standardised language for building sustainability.
In other words, to make sure that buildings effectively contribute to the climate neutrality objective set for 2050, a harmonised approach across the EU is required.
Well, first the good news. The European Commission and its scientific division the Joint Research Centre — working with companies, policymakers and Member States — have developed a framework to assess buildings sustainability known as Level(s).
This assessment framework covers everything from resource use, water use and thermal comfort to greenhouse gas emissions emitted during a building’s whole lifecycle. This framework can be used by any Member State and offers a one-stop shop for assessing the sustainability of buildings. It has been extensively tested and is expected to be integrated into regulations and policies at EU and/or national level in the coming years.
Now, the bad news. Some European countries are breaking with the objective of harmonisation. For instance, France is proposing a new methodology known as a ‘dynamic LCA’ within the remit of its national 2020 environmental regulation (RE2020).
Why is this a challenge? Well, a harmonised Level(s) approach means whether your new apartment block is built in Slovenia or Spain they are both assessed in the same way when it comes to sustainability. However, a new apartment block would be assessed differently if it were in France under the new French LCA proposal and this would create distortion of what is (or is not) a sustainable building on a Europe-wide level.
No scientific consensus on French LCA methodology
This has broader implications, for example, assessing how successful France’s new building stock is in terms of achieving EU’s decarbonisation goals compared to other countries. The comparison would not be ‘like for like’ because the calculations would be different.
Secondly, there are issues around building products. Rather than assessing all building materials equally, the French LCA proposal overestimates the potential benefit of biogenic carbon sequestration in construction products and their delayed CO2 emissions potential as long as the building is in place. This means bio-based materials such as hemp, cork or most significantly, wood, would have a distinct advantage over other building products.
Unfortunately, there is no scientific consensus on the benefits of temporary carbon storage, and such assessment runs counter to well established European standards of practice such as the international standard — ISO 14067 — which provides globally agreed principles and requirements of the carbon footprint of products.
Unlevel playing field for competition
Of course, the bigger business issue is that favouring one material over another and using an assessment that is not standardised across all Member States creates an unlevel playing field in terms of competition.
As we pointed out in our recent response to France’s RE2020 public consultation, “If entered into force, the [French] LCA would be in breach of Article 34 of the Treaty on the Functioning of the European Union since the method would institute a measure having equivalent to a quantitative restriction on imports prohibited between Member States.”
Then there is the challenge of delivering a circular economy. Buildings generate more than third of Europe’s waste and most Member States are determined to make it harder than ever to dump demolition waste in landfill in future.
Many companies, Knauf Insulation included, are pioneering new ways to feed their old products from demolition sites back into the manufacturing process and recycle scrap from customers. The methodology pushed forward by France disregards circular economy principles as the end of life impact from landfill or incineration is accounted for as negligible and as such does not incentivise recyclability.
Sustainability challenges and deforestation
Wood cannot be recycled in the same way and the final disposal of bio-based products inevitably involves either landfill and methane emissions or burning, neither a particularly positive environmental outcome. Plus, of course, this defers the disposal of building waste to future generations of tomorrow rather than finding the recycling solutions we need today.
This issue also connects to the role of the timber industry. Forests and woodland are carbon sinks that take many years to grow. There are also havens of biodiversity. To what extent would the French LCA proposal force a rethink of the forestry industry if new buildings are predominately manufactured from timber? Would there be enough national timber to meet demand (and be replaced) or would carbon-loaded imports be required?
France has long pioneered an exciting and ambitious approach to building efficiency, renovation and proactively driven social and economic agendas to create better buildings. But their new proposal for an LCA that is out of synch with the rest of Europe raises too many challenges and too many unanswered questions. There can only be one solution, a harmonised LCA approach that creates a level playing for assessing environmental impact, underlines the spirit of European cooperation, offers scientific integrity and is universally applicable to all new buildings in Europe.