Kieran has 15 years’ experience in legal private practice and in-house consultancy. He specialises in International Construction Arbitration, Energy, and Strategic Public Procurement. Kieran is a Fellow of the Chartered Institute of Arbitrators (FCIArb) and the Asian Institute of Alternative Dispute Resolution (FAIADR). He is a Member of the European Society of Construction Law, the European Commission High Level Construction Forum, and RICS World Built Environment Forum. Kieran is also Executive Committee Member of THE Arbitration and BUILD UP Board Ambassador.
BUILD UP: What is the status of EU policies and regulations on Life Cycle Assessment (LCA) in buildings? Which main EU policy milestones could be highlighted?
Kieran Morgan: The latest Intergovernmental Panel on Climate Change (IPCC) Report, ‘Climate Change 2022: Mitigation of Climate Change‘, reminds us that buildings need to decarbonise by 2050 in order to achieve the requisite carbon emission reductions. We know that the global building sector is responsible for 33% of final energy use and total direct and indirect energy-related emissions, and the challenge for all stakeholders in the built environment is to respond to building needs while reducing their overall environmental impact.
We also know that the building sector must achieve carbon neutrality by 2050 in order to meet Paris Agreement targets and that this is reflected in the European Green Deal. The European Green Deal highlights the fact that significant amounts of natural resources are used in the life cycle of buildings and so there is a need for harmonised Life Cycle Assessment (LCA) tools and databases for buildings to monitor their Whole Life Cycle (WLC) environmental impact performance in an open and transparent way. In an LCA of a building, all the material and process quantities are collated into a Life Cycle Inventory (LCI) and multiplied with the appropriate impacts for each material or process. The results are calculated and totalled to obtain the overall environmental impacts of the building.
EU initiatives have hitherto established a range of national and Member State-level measures to create methodological, data and reporting frameworks to introduce LCA requirements for buildings and projects. For example, WLC emissions accounting and reporting requirements have been introduced in France, the Netherlands and Denmark; building regulations mandating CO2 eq. limits for new buildings are planned in Finland (by 2025) and Sweden (by 2027), and amendments to public procurement regulations are being enacted in Germany and Switzerland to take into account LCA requirements for public buildings and projects.
Level(s) is the EU’s flagship framework for improving the sustainability of buildings, incorporating resource efficiency and circular economy principles. It aims to make it easier to integrate LCA into public projects. Level(s) has been referred to in the European Green Deal and follow-up EU policy initiatives such as the 2017 and 2021 Circular Economy Action Plans and it plays a key role in EU research and innovation.
BUP: Are EU Member States following a common regulatory framework in terms of LCA, or are there significant differences in its implementation?
KM: The ISO 14040 and 14044 standards provide an important framework for LCA, which is defined by ISO 14040 as the compilation and evaluation of the inputs, outputs, and the potential environmental impacts of a product system throughout its life cycle. This framework, however, leaves the individual experts, practitioners, and data developers with a range of important choices that can be individually interpreted, thus creating issues in terms of consistency, reliability, and comparability of the results of the LCA. Equally, the methodological assumptions behind the life cycle data can vary considerably, so that data from different sources can be un-interoperable. Therefore, the European Commission established the International Reference Life Cycle Data System (ILCD), an initiative developed with the aim of providing guidance and standards for greater consistency and quality assurance in applying LCA.
In terms of European circular construction (going from voluntary to mandatory regulation), some EU countries are implementing their own strategies and regulations. For example, The Netherlands government has set a timeline to transition to a fully circular economy by 2050 (‘De Circulaire Bouweconomie’) with a milestone target of reducing virgin raw material use by 50% by 2030. All public construction projects in Italy must comply with the Green Public Procurement Minimum Environmental Criteria, which includes targets from use of recycled or recovered materials and material re-use at end-of-life. France’s Environmental Regulation (‘RE 2020’) includes a requirement to measure the lifetime environmental impact of new buildings using LCA. Also in France, ‘La Lutte contre le gaspillage et à l'économie circulaire’ includes the principles of extended producer responsibility, which requires manufacturers to finance a product's end-of-life. In Sweden, mandatory climate declarations (‘Boverket’), which transparently disclose the climate impact of a building, have become a mandatory requirement for all new buildings since 2022.
One of the limitations of Level(s) is that it is not mandatory and falls behind the EU Taxonomy alignment goals. Several EU countries have supported the development of bespoke LCA tools and supporting databases for use by building professionals through various research institutes, for example, TOTEM (Belgium), ELODIE/INIES (France), Nationale Milieudatabase (the Netherlands), and LCAByg (Denmark). The Buildings Performance Institute Europe based in Brussels has also spotlighted the need to mainstream and harmonise WLC greenhouse gas emissions methods and support, and the various EU initiatives have sought to mainstream WLC assessment and make it more accessible to practitioners by addressing barriers.
“One of the limitations of Level(s) is that it is not mandatory and falls behind the EU Taxonomy alignment goals”
BUP: How is LCA linked to Life Cycle Thinking (LCT)? What about Life Cycle Costs (LCC)?
KM: Life Cycle Thinking (LCT) is a framework that takes a holistic view of a product, process, or service from extraction of raw materials through to production, consumption or use, to end-of-life. It considers the environmental, social, and economic impact over the entire life cycle with the aim to reduce resource use and emissions and improve socio-economic performance. The key to LCT is to avoid burden shifting. A Life Cycle Assessment (LCA) quantifies LCT and assesses the emissions, resources consumed, and pressures on health and the environment that can be attributed to different goods or services over their entire life cycle. It seeks to quantity all physical exchanges with the environment, whether these are inputs in the form of natural resources, land use and energy, or outputs in the form of emissions to air, water, and soil.
LCA considers the product’s full life cycle from extraction of raw materials through production, use and recycling, up to waste disposal. LCA is therefore a powerful decision support tool to make consumption and production more sustainable. Per ISO 14044, LCT meets sustainability objectives as it provides a robust tool to decision-makers in the supply of materials that balances current and future needs of the global community. LCT is an important tool as industry and society embrace the shift to a circular economy and the LCA standards references support for the United Nations Sustainable Development Goals (SDGs) 12 and 13.
LCC considers all the costs that will be incurred during the lifetime of the product, work or service including purchase price, operating costs, and end-of-life costs. LCC may also include the cost of ‘externalities’ such as greenhouse gas emissions under specific conditions laid out in the Directives. By applying LCC, Public Buyers consider the costs of resource use, maintenance and disposal which are not reflected in the purchase price, and this will often result in a ‘win-win’ situation whereby a greener product, work, or service costs less overall. Where LCC calculates the costs of a product throughout its life cycle (which can include giving a monetary value to environmental externalities), LCA assesses the environmental impacts, such as GWP, over the life cycle.
BUP: What tools are available to support building and construction companies to apply life cycle concepts and reduce their environmental impact?
KM: If you are using Level(s) as the framework for assessing the sustainability performance of buildings, you can access the European Commission’s free Calculation and Assessment Tool (CAT) to help you create Level(s) assessments for your projects. CAT is there to support you to complete LCA using Level(s) during the different phases of building design, construction and maintenance or de-construction.
Construction companies can measure the environmental impacts of potential building sites through an LCA, such as for land sales, refurbishments, or city planning, to perform the LCA of an infrastructure project, or achieve credits for green building certification schemes such as LEED and BREEAM. Many certification schemes around the world include LCA credits:
To calculate a building’s LCA, you need the project’s bill of quantities and the calculated energy performance of the building. For example, an LCA tool such as One Click LCA integrates Building Information Modelling (BIM), Revit, Excel, IFC, IESVE, energy models (gbXML), and other tools, which makes it easy to import a design and automate the complex LCA calculations. This makes the process easy and fast, and economically feasible to integrate into the early design phase. Most LCA tools come with an LCA database of building materials, which allows users to map material choices from their model to the software. Assessing the impacts of building materials is a necessary part of calculating a building’s LCA and an LCA database helps to achieve that goal.
“Assessing the impacts of building materials is a necessary part of calculating a building’s LCA and an LCA database helps to achieve that goal”
BUP: How is LCA reflected in the EU Framework Level(s)?
KM: Level(s) is a scientific, harmonised, and transparent methodology with the potential to mainstream sustainability building assessment. The Level(s) framework was developed for residential buildings and offices; however, its principles are broadly applicable to most building types. The premise of the Level(s) framework is for EU Member States to use a common set of Indicators and Methodologies to measure environmental performance in buildings, allowing for direct comparison of best practices, knowledge sharing, and setting evidence-based targets.
Level(s) Macro Objectives are:
Level(s) guides EU policy, for example, in the proposed revisions of the Energy Performance of Buildings Directive (2010/31/EU), which requires the calculation of the Life Cycle Global Warming Potential (GWP) for 'Big Buildings' from 2027 and for all new buildings by 2030, and the Energy Efficiency Directive ((EU) 2018/2002 amending Directive 2012/27/EU). Level(s) is being integrated into the Sustainable Finance Taxonomy as well as in the new set of voluntary 'EU Green Public Procurement Criteria for Public Buildings, Office Buildings and Schools' (2023). Meaningful links are expected with the '2050 Roadmap for the Reduction of Whole Life Carbon’.
Taking a closer look at Level(s) Indicator 1.2 to design, assess and verify Life Cycle GWP of buildings, we can split a typical building life cycle into three parts (Modules):
In order to achieve zero embodied carbon, a business must be net energy positive. But the question is, how 'near' to zero must a Nearly Zero Emission Building (NZEB) be, and how long does/will it take? If we consider a typical building life cycle to be 50 years and compare a ‘normal’ building using grid electricity and mains gas to a building with onsite renewables (to be net energy self-sufficient), or better yet, a building with onsite renewables (to be highly net energy positive), we can calculate that in the beginning of the building’s life cycle (Module A, Years 1-2), the ’normal’ building will have the lowest cumulative life cycle carbon of 1,000 kg/m2/yr (vs. 1,900 kg/m2/yr), but at the end of the building’s life cycle (Module C, Years 48-50), the building with the most onsite renewables will achieve cumulative life cycle carbon which is net energy positive between -250 and -500 kg/m2/yr (vs. 2,750 kg/m2/yr). Therefore, Zero Embodied Carbon requires Net Energy Positive.
Level 1 is for every stakeholder because it is conceptual and offers the greatest opportunities to lock-in benefits. What Level(s) adds to EN 15978 is a minimum scope definition for embodied carbon and default services for various scenarios. How can your business ensure good execution and reliable results? The focus needs to be on requirements and deliverables. Businesses need to train staff and stakeholders before the project commences, including training on the Level(s) framework in the call for tender, and engaging a strong Project Manager for coordination and planning. The focus must then turn to materials and design. You must identify the products and materials through rigorous selection and design for disassembly and reversibility (adopting circularity principles).
BUP: What are the biggest challenges in implementing circularity principles in buildings?
KM: Based on a building's full life cycle, the building sector is responsible for:
Low carbon solutions (which adopt circularity principles and design for adaptability and deconstruction) reduce waste and optimise material use. Embodied carbon can be effectively reduced by taking a circular approach, for example, re-using concrete decks which can save up to 90% of concrete embodied carbon in a building (concrete typically accounts for 10% of all embodied carbon in buildings). Yet, in an era of steel, concrete and glass structures, only 6% of construction materials are reused in an industry responsible for 40% of CO2 emissions.
Whole Life Carbon (WLC) is the embodied and operational carbon taken together. It measures the GWP contributions of a building along its life cycle from 'cradle' (the extraction of raw materials that are used to construct the building) to the 'grave' (the end of the building's use/life cycle). EU policy is starting to address WLC in buildings and a number of different businesses/actors within the built environment are setting out roadmaps and quantified strategies.
There are practical hurdles to overcome by adopting circular principles in construction. One such hurdle is the need to develop digital ‘materials passports’ to capture and store information on the materials used, for evaluation at a later date. Another is the fact that an increasing number of projects adopt collaborative Building Information Modelling (BIM) models, which currently do not recognise or operate with recycled materials. Typically, developers and contractors showing the best of intentions still find it hard to overcome the lack of a standardised means of evaluating and incorporating recycled material into their projects.
“An increasing number of projects adopt collaborative Building Information Modelling (BIM) models, which currently do not recognise or operate with recycled materials”
In my experience, implementing circular construction on building sites involves recasting or reusing materials, which can prove more expensive and produce more CO2 than buying and using new/virgin materials. There are some signs that recycled materials are becoming more accepted by developers, who are concerned with public perception and net zero commitments, and there is also increasing interest and perceived commercial value in constructing buildings that can be reimagined and reconfigured in situ, without the need for demolition and rebuild.
The shift to greater circularity in construction will have a disruptive effect on the industry, but there are ways to accelerate the process:
BUP: Can you present a best practice example from projects or national initiatives?
KM: The Irish Green Building Council (IGBC) offers an introductory course to help developers and contractors understand the methodology and mechanics of Level(s) Indicator 1.2 and how to carry out a compliant Level 2 assessment using the online One Click LCA tool. Indicator 1.2 takes a WLC approach, incorporating design decisions that are also addressed in some of the other Indicators, such as Indicator 1.1 (use stage energy consumption), Indicator 2.1 (bill of quantities, materials, and lifespans), Indicator 2.2 (construction and demolition waste and materials), Indicator 2.3 (design for adaptability and renovation), and Indicator 2.4 (design for deconstruction and recycling). This gives the design team an overarching view when considering the future of any building project.
IGBC is partnering with eight other European Green Building Councils to mainstream sustainable buildings in Europe through greater awareness and use of the specified Indicators within Level(s). The selected indicators are LCA, LCC, and Indoor Air Quality (IAQ). The project partners developed a Best Practice Guide to Support Incorporating Level(s) Indicators into Public Procurement Processes, which consists of:
