Introduction to life-cycle scenario settings
The motivation to require a “life cycle GWP” in a regulatory perspective is the need to inform the market actors about the relative impact of the different parts of the building cycle in a uniform format based on the different information modules and building parts. The construction stage A1-A5, representing ‘as built’, can be evaluated by real data and does not need scenario settings for the construction stage. Although a climate declaration covering a full life cycle can never be verified by real data, scenario settings can be developed to cover the future parts on a common basis in a harmonised way. Subsequently, the influence of the person responsible for the LCA calculation is being minimised. One must be aware of the fact that the basic assumption for such a scenario setting is very simplified, where the building after the construction stage is used during an analysis period of 50 years and then assumed to be demolished, while it most likely will be rebuilt at this stage. The mandatory demolition (module C1) is not what the society aims at or what is likely to happen; it is just a simplification that describes ‘what happens if’ when such a linear life cycle is assessed (or a worst-case scenario).
By introducing an LCA covering a full life cycle, it could in theory be justified to use materials with a higher climate impact in the construction stage as part of a more durable technical solution if the overall impact is then reduced over the analysis period. This thinking is important from a regulatory perspective and as an instrument for climate improvement and understanding the overall impact. We notice that one option is to only regulate such aspects that can be verified, typically the building 'as built', or to expand, for instance, a limit value to include the full life cycle based on scenario settings. In the latter case, the rules for these scenario settings must be as precise as possible. This is to ensure that regardless of which consultant calculates the impact from the scenario-bases modules, the result remains the same. It can, of course, be disputed if a limit value should include such value bases scenario settings that cannot be verified and based on scenarios and therefore only account for A1-A5 that can be evaluated. This problem regarding limit values is dealt with in a separate project parallel to this one, and therefore not dealt with in this report.
To account for a whole building life cycle, it can always be motivated by the fact that it gives supportive information, and where there are significant aspects that affect the future scenario, these must be handled with an uncertainty assessment. The development that we can see now for construction products – that it is asked for – is that an EPD for a construction product shall include information for the full life cycle, and the wish is the possibility to reuse EPDs at the building assessment level. In reality, often only the modules A1-A3 can be controlled by the material manufacturer; in that respect, they are the only part of the life cycle where the producer can guarantee the life cycle performance. Other parts of the life cycle may vary and they are often out of the manufacturer's control. In most cases, the scenario settings for a construction product are very free to set for modules A4 to C4, which is why the information from an EPD seldom can be used as a source on the building level as it is now.
Nevertheless, the regulators would like that future so-called Product Category Rules (PCR) for a specific product group or types of construction products will be developed to include more generic applicable end-of-life scenarios. For instance, it is suggested that the EPD for modules C3-C4 and D includes a 100% scenario. In an EPD, a 100% scenario is several scenarios for C3 and A4 that can be (re)used to create any desirable waste scenario. Such user-defined scenario can be a mix on the building level based on real end-of-life data, or defined per country based on country-specific settings set by national regulators, etc. This kind of scenario setting is in accordance with the new CPR Acquis process, which describes a needed development for future regulated EPDs. Such scenarios are then typically based on European average scenario settings. Therefore, it is most likely that the market will respond by mandating material producers to define the scenario settings in the most representative way to be used in an average European context. This kind of EPD information can then be used for benchmarking with other producers of the same product type. However, it is not representative for a specific product in a specific building.
As exemplified in the CPR Acquis process, the 100% scenario approach suggested for stage C for construction products, EPDs can then, when used on the building level, easily be modified to be representative for any nation or scenario setting for any waste mix. When this text is written, the outcome from the part of the CPR Acquis process dealing with EPDs for construction products is not published. It is, however, likely that CPR Acquis defines different 100% scenarios relevant for the European averages that then can be reused on the building level and adds a mix based on these 100% alternatives per product. The prerequisite in EN 15804 (where the construction product sector’s opinions are accounted for) is that any construction products should be assessed in the context of its final intended use, which is why the final assessment is only valid in the specific project and takes the specific requirements into account. If the aim is that the EPD for construction products should support the assessment on any construction work level, the scenario has to be modular and include the background information for calculation in any scenario-based information module. If the EPD, for instance, only includes a single scenario-mix for a specific country for stage C, such results will, in practice, only be valid for benchmarking within an EPD PCR product group, but they will never be applicable to real-life conditions.
The above-mentioned scenario setting modularity and flexibility can also be achieved by reporting the data source used for the LCA calculation, rather than a fixed calculated GWP result. An advantage of this approach is that parts of the scenario settings can be regionalised or country-specific. For instance, the current biocomponent respective fossil mix used in diesel for transportation purposes in different regions or countries can easily be adjusted if the common scenario settings described the equation to achieve the GWP result, rather than only the resulting GWP figure without its underlying data. If the scenario setting for transportation is divided in different parts, such as fuel type, vehicle type, and energy use, and if all this information is reported as scenario settings for a building or part of an EPD for a construction product, such flexibility may be achieved.
One could ask if this sort of a very fine-grained scenario setting may be practical for utilising LCA tools and ensuring expeditious assessment processes on a building level. The answer is that these kinds of features are already included in most LCA tools used for buildings; if not, it will be a development that users will ask to be implemented. This kind of parameterised scenario setting, 100% modularity, will both streamline and make the calculation results more robust.
General guidance for scenario settings in the context of European legislation
The scenario settings for a whole building life cycle LCA are preferably found in commonly agreed specifications that are given in the product category rules (PCR) for buildings, namely EN 15978 and its latest version, and if relevant, also Level(s), as is referred to in the EPBD directive concerning a few aspects. Besides these more general scenario settings found in the PCR standard, complementary specifications are required if the result should be uniform. Such specifications will likely be published in a delegated act related to the EPBD directive and its mandatory climate declaration for new buildings. So far, a few specifications are known for the so-called “life cycle GWP” indicator [(kg CO2e/(m²∙y)]. It is currently known that the functional unit should be reported per useful floor area and the integrated climate impact is calculated as GWPtotal over an analysis period of 50 years. The scope of building system parts to account for in the inventory is given as listed in Level(s). Besides the so-called overall life cycle GWP indicator result covering modules A to C, it will also be needed to report B6 energy use separately and stored in national databases that will be an interconnected database within the EU (see EPBD Article 19).
There is an aim that the climate declaration for buildings shall be supported by information from environmental product declarations (EPDs) for all kind of resources used during the building’s life cycle. EPDs are based on product calculation rules for construction products, as defined in EN 15804 and its latest version. It is likely that this kind of EPD will be mandatory, and the ongoing CPR Acquis process will define how this EPD will be defined and approved. If a building climate declaration is asked for as part of a building permit, it must be based on generic data, and if a climate declaration is asked for 'as built', it can be based on specific data. When a climate declaration 'as built' is asked for, the goal is that a significant number of representative EPDs for specific products (as delivered to the construction site) shall be used. In order to report the amount of specific data used on the building level, the amount of specific data actually used in an individual EPD must also be added. This requirement to report the actual amount of specific data used in an EPD, in respect to the GWP indicator A1-3, is currently only required by one program operator, namely EPD International.
What is known about the scope of the new EPBD directive is it that there will be a climate declaration in 2028 and the limit value added to the declaration as such that will be required for all new buildings from 2030. Furthermore, by 1 January 2027, Member States must publish a roadmap detailing the introduction of limit values on the total cumulative life cycle GWP and notify this to the Commission. However, this describes the minimal level of implementation, and limit values can potentially be added to national legislation for, e.g. the construction stage (A1-A5), and be based on the same modular information that the EPBD climate declaration is comprised of. In order to ensure that GWP results will comply with set limit values, a climate declaration or mandatory complementary reporting to the climate declaration is necessary. They should be more transparent than the single-value life cycle GWP indicator mandated by the directive. This enhanced reporting is needed for facilitating limit values, particularly in scenarios where the full life cycle is not considered. Although the potential of including limit values is addressed in another project, it is worth noting that they do not necessarily have to include all building information modules and life cycle stages.
Moreover, a national limit value may require a climate declaration as part of the building permit and some may require a 'as built' climate declaration, or both. Presently, this is not defined in the EPBD directive climate declaration. The recommendations given in this report aim to provide guidance on defining scenario settings that are as representative as possible, following on a stepwise approach.
Where a simplification is possible for any scenario setting and when a European common average approach can be used as a default starting point, this will be a preferable alternative. If this is not possible, a more localised scenario is needed; such specifications can be developed by those countries that ask for this, preferably based on the same methodology approach as applied in the European scenario setting. Such a tiered approach may also – in theory at least – include specifications for a local context related to the actual building site.