Standfirst: As Module D is seemingly left out of a landmark new homes benchmarking report, Nigel Headford, Chief Executive at the Council for Aluminium in Building, explains why ‘whole life should mean whole life’ when it comes to Whole Life Carbon calculations.
Feature: The launch of the Future Homes Hub (FHH) Whole Life Carbon (WLC) Benchmarking Report is a welcome ‘first step’ towards providing developers with the real-life data to both understand and reduce carbon in new homes.
Building a shared dataset of WLC assessments to measure the current performance of new homes more accurately, the FHH report references established frameworks such as EN 15978 and the RICS Whole Life Carbon Assessment (WLCA) for the Built Environment (2nd Edition).
Module D matters
The RICS guidance states that ‘…a full [WLC] assessment will also include Module D’, which concerns the carbon impacts and savings that occur after a building’s life ends, when materials are reused, recycled, or recovered.
It goes further in Section 3.1, confirming: ‘For new-build assets, either buildings or infrastructure assets/civil engineering works, all life cycle stages must be assessed, including Module D.’
Despite these clear endorsements of the need for its inclusion, Annex C of the FHH WLC Benchmarking Report indicates that Module D has, instead, been ruled out.
Module D considers the possibility that the materials used in a building’s construction, such as aluminium or steel, can be recycled and used instead of virgin product in the future.
As circular economy principles gain traction in built environment policy, and as Environmental Product Declarations (EPDs) to EN 15804+A2 now include Module D data as mandatory, excluding this stage means the long-term environmental value of durable, recyclable materials is overlooked.
Without Module D, there is no way to ensure that the new homes of today do not become the waste of tomorrow.
Risk of distortion
Materials designed for circularity may appear more carbon intensive if only upfront (A1–A5) and end-of-life processing (C1–C4) stages are assessed. The benefits of reuse and recycling are omitted, potentially impacting material choices and underestimating long-term performance.
While we recognise the pressure to balance technical accuracy with simplicity to encourage participation in schemes like the FHH WLC Benchmarking Report, at the end of the day, we need to get it right – and not lead people to underestimate the complexity of WLC.
As benchmarking becomes more influential, consistency across methodologies is essential. Aligning with EN 15978 and the RICS WLCA ensures both comparability and credibility.
The Council for Aluminium in Building (CAB) fully supports data-capture initiatives and considers the FHH’s benchmarking efforts so far to be a constructive starting point. But we urgently need clarification of the methodology to ensure reliability and reflect true whole-life impacts.
‘Life should mean life’ is a phrase often used in support of whole-life tariffs for the perpetrators of the most serious crimes, and when it comes to Whole Life Carbon (WLC), the same sentiment applies. In this case, that means the inclusion of Module D.
For more information about CAB, visit www.c-a-b.org.uk. Alternatively, email enquiries@c-a-b.org.uk or call the team on 01453 828851.