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UK carbon budget plan ‘Halfway There’

by Simon Foulds

The UK government’s new Carbon Budget and Growth Delivery Plan (CBGDP) has been welcomed by the Building Cost Information Service (BCIS) as a step in the right direction. Still, it warns that it falls short of addressing whole-life carbon reporting in construction.

According to BCIS executive director James Fiske, who also chairs the Built Environment Carbon Database steering group, the plan focuses heavily on operational carbon reduction but misses the opportunity to introduce mandatory measures for assessing and managing whole life carbon emissions in buildings.

“We are quickly running out of chances to reverse emissions in the built environment,” Fiske said. “While the plan’s focus on reducing operational carbon and tackling embodied emissions in materials such as steel and cement is positive, mentions of whole life carbon reporting are limited to encouragement rather than enforcement.

“As a sector, we have the tools, data, and expertise to implement whole life carbon assessments accurately and consistently. What’s needed now is government commitment through policy, not a plan that’s halfway there.”

Built environment responsible for a quarter of UK emissions

The UK Green Building Council estimates that around 25% of national emissions come directly from the built environment. Research from the BuildZero project found that implementing regulatory limits on embodied carbon at a national level would be significantly more effective than local authority-led initiatives. Nationwide limits could reduce projected emissions by as much as 31%, the study suggested.

The CBGDP sets out the government’s intention to promote Whole Life Carbon Assessments (WLCAs) across all stages of a building’s lifecycle, from design and construction through to demolition and reuse. However, these measures will not be encouraged until the fifth carbon budget, meaning implementation is unlikely before 2028.

Incremental progress, delayed impact

The plan also highlights other initiatives relevant to the construction and infrastructure sectors, including incentives to reuse existing buildings, promote circular economy principles, and scale up the use of low-carbon and carbon-negative materials. The government confirmed that it will continue developing policies to strengthen the low-carbon industrial materials market.

Forthcoming strategies include the Circular Economy Strategy, aimed at reducing industrial waste and increasing reuse, recycling, and remanufacturing efforts, alongside the Future Homes Standard and Future Buildings Standard.

These developments follow a significant impact assessment on embodied carbon, commissioned by the Ministry of Housing, Communities and Local Government and delivered by AECOM. The report recommended establishing a national carbon dataset, subsidising Environmental Product Declarations (EPDs), and upskilling construction professionals in whole life carbon analysis and alternative design methods.

A call for urgency

Fiske cautioned that 2028 is far too late to begin serious action on whole life carbon. “AECOM’s report provided an evidence-based case for a carbon reporting mandate,” he said. “Given recent political uncertainty around climate commitments, standardising how we assess all emissions in the built environment is critical. It could be the difference between meeting or missing the UK’s net zero targets.”

The Carbon Budget and Growth Delivery Plan represents progress towards carbon reduction in the built environment, but the absence of a firm mandate for whole life carbon reporting risks delaying meaningful impact. With construction responsible for a quarter of UK emissions, industry leaders are calling for regulatory clarity and accelerated action. To achieve net zero by 2050, embedding whole life carbon assessment into national policy will be essential, not optional.


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