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planning regulation. The GLA has required the submission of these calculations for major or referable projects since 2020. They indicate benchmarks but no limits. Other local authorities are following suit, but in different ways, depending on location. To summarise, it’s fair to say we have all the guidance we need; what’s required is the legal act of making it mandatory and measuring consistently across the UK and upskilling teams to do that. Part Z can help make a start.


What is Part Z & why do we need it now?


While it is well established that measuring and reporting whole life carbon is essential for emission reductions, it is still not a mandatory requirement within the UK Building Regulations. It is clear there is an emerging variance in how it is treated within planning authorities – and hence within design practices. As a result, in 2021, a group of five experts – multidisciplinary sustainability professionals – developed Part Z. This was a proposal for amendments to the Building Regulations to mandate the reporting of WLC and eventually, the limiting of carbon emissions. The document is available online, and its clear intentions can provide a needed direction to the industry. Part Z1 plans to help normalise the use of WLC assessments within the building design process, to identify easy wins and key contributors early on, and then ways to reduce the WLC impact. Part Z2 is intended to “discourage excessive and unnecessary use of resources within the built environment, by setting a reasonable standard of efficiency for the upfront embodied carbon intensity of the building.” Part Z1 is envisioned to gather quality assessment data as a first step, and use it to determine realistic national targets for upfront embodied carbon for Part Z2.


How could Part Z drive a sustainable built environment? Key to carbon reduction is consistent measuring with defined scopes, but also using the outcomes to influence design. Part Z would bring a steady approach to measure both operational and embodied carbon, so it becomes part of the design thinking. For better built environments, analysing operational emissions early on would help ensure that buildings are designed using passive principles, with efficient systems, low carbon technologies


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to minimise energy demand, and hence emissions.


For embodied carbon, iterative analysis could help focus on minimising up-front carbon by using low carbon materials suitable for the building use and requirements, while not ignoring the durability and replacement cycles (Modules B-C and D). Early measurements would help draw attention towards reducing the upfront embodied carbon, which is key in the current climate. It is the largest proportion of embodied emissions in the WLC and will be released in the immediate future for buildings being designed now. However, for a well-informed decision it is essential to take a long-term view – to understand what operation, maintenance and replacement cycles mean through WLC results. Part Z could be used to find that balance, between upfront and WLC and then between embodied and operational. Furthermore, the improvements and reductions could be fairly compared between different projects regardless of where and who is doing the analysis within the UK; this helps to scale-up. Regulating WLC would further drive the retrofitting of the existing building stock instead of building a new, supporting circular economy.


How is it going to bring challenges and opportunities for key players? We need to recognise that WLC is a skilled task, therefore one of the key challenges is upskilling. This applies to clients, regulatory bodies, designers, contractors, and manufacturers. For clients it is key to understand what they are committing to, for regulatory bodies to comprehend data and review the proposals presented during planning; for contractors and manufacturers it means upskilling the teams with WLC methodology to allow regular monitoring required on site so set limits can be achieved.


The other challenge is the associated cost, as clients will have to pay for specialist services, and depending on the pace of up- skilling, others might have to rely on limited third party verifiers, hence additional cost. But the investment brings necessary, long-term benefits. Following this approach will add to certainty in the process and outcomes once the initial phase of introduction is over, and will bring opportunities to incentivise a low carbon material supply chain. When


Part Z is intended to bring a step change; the regulation of whole life carbon has been supported by more than 100 firms of developers and architects, including Hawkins\Brown


regulation is introduced, it will allow long-term investment to be made. This will directly benefit the innovative products that currently struggle to get traction and certification, due to the large costs involved. This will also mean that existing buildings can be looked at as ‘material banks,’ and the first instinct will be to reuse and not build new.


Part Z’s wider impact


This one act can bring a huge shift in how we design and assemble almost anything. Currently, there is a huge gap as only a small group are following the approach, but with amendments to regulations this will change drastically. This will mean that everyone follows consistent methodologies and there is transparency, and will build up the quality database that the industry urgently needs. But the key transition it will bring is our outlook on the environments we have built already, including use of circular economy principles, using our cities as material banks, and urban mining to reduce the emission figures.


The power of Part Z will be escalating the demand to invest and research into innovative low carbon materials and new techniques of construction (using existing materials) and how we record and use material information. We have seen a huge uplift in discussions and explorations around structural efficiencies, retrofit and low carbon materials such as timber as an outcome of WLC conversations. This needs to be carried forward for our design thinking to expand, and for the phasing out of outdated carbon-intensive construction approaches that are clearly not good for the health of our planet. To conclude, Part Z can bring a step


change, and this regulation of WLC has been supported by more than 100 firms of developers and architects, including ours.


Shikha Bhardwaj is lead sustainability designer at Hawkins/Brown


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