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By the 15 October responses to the Department for Communities and Local Government (DCLG) consultation on 鈥渁llowable solutions鈥� will need to be in.

All new homes are supposed to be zero carbon by 2016. This is clearly not going to be achieved. Obviously therefore the DCLG has decided to change the rules so that 鈥渢argets鈥� can be met. Brilliant!

Despite my cynicism this is not such a bad thing as it allows for a broader range of alternatives to reducing carbon emissions to come into the mix. Renewables etc are part of this.

Embodied carbon emissions can amount to more than half of the total carbon emissions over the life of a building

What I and many others are interested in having included as an allowable solution is embodied carbon - the emissions associated with the materials that constitute a building. Embodied carbon emissions can amount to more than half of the total carbon emissions over the life of a building.

These emissions are not however covered by current legislation. These are some of the main reasons why embodied carbon should be included as an allowable solution:

Delivers substantial CO₂ emissions reductions during the construction process.

• These emissions reductions are delivered up to practical completion.
• These reductions are therefore 鈥済uaranteed鈥� and not reliant on occupational behaviour.
• These reductions are measurable and auditable.
• These reductions are delivered 鈥渢oday鈥�, and not over a future, post completion period.
• Encourages localism by encouraging short distance delivery.
• Encourages design innovation in components and systems.
• Encourages design innovation with regard to assembly and disassembly of buildings.
• Encourages material recycling and reuse of materials.
• Encourages reuse of existing buildings, which has cultural and social benefits.
• Improves efficiency in construction.
• Encourages long term thinking by designers
• Encourages more holistic thinking in building design.
• These reductions are predominantly low to zero cost.
• They are already covered by existing standards (eg BS EN 15978 and others)

Allied to this is the concept of whole life carbon emissions. This covers all the energy from both materials and occupational use over (usually) 60 years. If you want a proper, holistic, carbon emissions assessment of a building over its life then this is the solution. Such assessments are more accurate, are cheaper to achieve reductions, and avoid the unintended consequences of only looking at energy in use as currently required.

So if you agree with this, lets start with embodied carbon and evolve to whole life, it鈥檚 not too late, make your submission on allowable solutions. Go to:

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Simon Sturgis is managing director of Sturgis Carbon Profiling