Jordan, Nino; Grubb, Michael; Butnar, Isabel; Sato, Misato; (2022) Joint response by climate policy experts from UCL and LSE to BEIS Call for Evidence: Towards a market for low emissions industrial products. University College London (UCL): London, UK.

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Abstract

A. Executive summary// A.1. Carbon intensity standards for final products (e.g. buildings, cars) have a higher de- carbonisation potential via inter-material substitution than intermediate product standards (e.g. cement). However, they are also more complex. Government can combine maximum carbon intensity standards for intermediate and final products to optimally accelerate de-carbonisation towards net zero.// A.2. It does not make sense to calculate a building's whole lifecycle carbon emissions by assuming that the carbon intensity of heating will remain constant over the next 50-70 years while the electrification of heating is likely to rise and the carbon intensity of the grid to decline. Therefore, carbon intensity standards should align whole lifecycle carbon emissions assessments with plausible heating decarbonisation pathways rather than relying on present carbon emissions factors for heating.// A.3. There are many uncertainties associated with the use of benchmarks that presuppose CCS deployment at scale. Better avoid such potential bottlenecks for decarbonisation and opt for other definitions of maximum carbon intensity standards.// A.4. Most climate mitigation scenarios for sticking to the Paris targets assume the use of bioenergy with CCS (BECCS). Intermediate storage of sequestrated carbon via the use of biomass in buildings and infrastructure is preferrable to direct energy use. Therefore, government should use carbon intensity standards to incentivise the use of carbon sequestrating biomass in construction.// A.5. Certain carbon intensive building products are well recyclable and potentially reusable. However, the promise of future recyclability many decades ahead should not distract from the need to decarbonise in the present and near future. A.6. Simplified estimates for maximum carbon intensity standards can be acceptable where the aim is tapping into the decarbonisation potential of inter-material substitution.// A.7. Government can use public sector procurement as the vanguard of lead market generation.// A.8. There is an excellent case for working towards the adoption of border carbon adjustment mechanisms and maximum carbon intensity standards in parallel rather than choosing between one or the other.// A.9. Maximum carbon intensity standards should be combined with targeted subsidies to create green lead markets and accelerate the transition to net zero.

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