Bionova SBE0122

Written evidence submitted by Bionova Ltd (OneClick LCA), Elmhurst Energy, Targeting Zero, The Construction Carbon Footprint Scheme


How carbon emissions from the built environment can be controlled and mitigated by a Government endorsed voluntary certification programme.


  1. This paper has been prepared by the Construction Carbon Footprint Scheme. We have been established by a team of experienced professionals working in the construction and real estate industry. We are supported by some of the leading experts in this field and we are backed by Imperial College’s Grantham Institute for Climate Change and the Environment’s Greenhouse Program, a central part of London’s new Centre for Climate Change Innovation.


  1. We aim to address the following question raised in the Environmental Audit Committee’s call for evidence on sustainability of the built environment:


2.1.            What methods account for embodied carbon in buildings and how can this be consistently applied across the sector?


  1. We touch on the question:


3.1.            How can the planning system, permitted development and building regulations play a role in delivering a sustainable built environment? How can these policies incentivise developers to use low carbon materials and sustainable design?




4.1.            For our sustainable future, we need to drive towards net zero carbon emissions generated by the construction and use of the homes, offices, factories and other buildings that are required by society.


4.2.            For us to achieve net zero carbon emissions from the built environment we need to measure, mitigate and certify carbon emissions associated with each element of a building’s lifecycle.


4.3.            Creating a straightforward certification scheme will benefit multiple stakeholders.


4.4.            The grading of the certificate issued based on comparison against benchmarked projects will enable enforcement, as well as encouraging competition among developers.


4.5.            For a building to be considered truly Net Zero, it needs to be assessed at each stage of its life, residual CO2 emissions should be calculated and offset, and this needs to be certified on an ongoing basis.


4.6.            Each stage needs to be considered during the design process, with project teams project teams encouraged to minimise the impact of each stage.


4.7.            Various life cycle carbon assessment software tools are available though there is no standardised assessment process or accreditation.


4.8.            For a credible certification scheme, that allows the enforcement of carbon emission reductions from construction and use, an ‘accredited carbon assessor’ program will need to be created.


4.9.            While anticipated carbon performance of each element should be considered and assessed at the design stage, ensuring actual carbon performance for each stage is calculated and offset in order to achieve net zero should be the responsibility of the people or organisations that own that part of the process, as per the points below:


(explanation of stages in main body of text)


4.10.            Upfront emissions from the product and construction stages (A1 - A5) - need to be assessed through design and construction, offsets acquired and certificate issued at practical completion.


4.11.            ‘In Use’ embodied carbon emissions (B1 - B5) need to be assessed on an annual basis alongside net operational energy and water use (B6 - B7), the residual CO2 calculated and offset, and a certificate issued at that time in order to be net zero carbon on an ongoing basis.


4.12.            End of life carbon emissions (C1 - C4) need to be considered at the design stage. Carbon emissions from this stage are calculated and should be offset at that point.


4.13.            There is already an appetite for those undertaking construction projects to address A1 - A5 emissions, as well as from local authorities and financial institutions. Consumers are increasingly keen for a greater understanding of the environmental impacts of products and services to inform their decisions.


4.14.            This paper focuses on the case for an independent certification scheme using a network of accredited assessors that can be used as a mechanism to demonstrate carbon performance of buildings. It would align the interests of the government, financiers, developers and consumers by providing a means for the carbon efficiency of construction projects to be publicised and mitigated, as well as a framework to control and drive down carbon emissions from construction.


4.15.            This will create accountability in the construction industry for carbon emissions; the first step required in the wholesale revolution required to create a more carbon efficient construction industry.


Graphical user interface, table

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Source - Whole life carbon assessment for the built environment RICS professional statement, UK 1st edition, November 2017


5.1.            Globally, the built environment accounts for 39% of total carbon emissions. This figure includes ‘embodied carbon’ and ‘operational carbon’ emissions. Embodied Carbon (approximately 11% of global emissions) includes the ‘upfront’ carbon emissions from the construction process (A1 - A5), as well as maintenance and repair throughout the life cycle of the building (B1 - B5) and demolition at end of life (C1 - C4). Operational emissions (approximately 28% of global emissions) are those associated with the energy and water used through the use of a building.


5.2.            To date, most technological and all regulatory efforts have been aimed at addressing operational emissions. Studies show that with current trends in construction on the one hand, and the pace at which technologies to make buildings more energy efficient are evolving on the other, embodied carbon emissions will overtake those caused by operational energy and water in the near future[1] [2]. Anecdotally this is already happening with a number of new construction projects as operational efficiencies improve.


5.3.            The importance of tackling upfront, and lifecycle embodied carbon emissions cannot be overstated.



6.1.            Different Stakeholders with Common Interests. Local authorities are responsible for implementing increasingly demanding carbon emission reductions through planning requirements. Financial institutions and funders providing finance into the construction sector are under increasing pressure to ensure what they are funding is ‘doing no harm’[3]. Large funds of ‘green’ capital are being made available, with a desire to lend into ‘green’ construction projects[4].  Developers are providing buildings to a consumer market ever more conscious of supply chains and the environmental impact of products and services, and they want to be sure that any performance statistics they publicise can be held up against those of their competitors on a level playing field. Consumers want to be able to make choices on the spaces they inhabit based on a wider range of issues including environmental impacts.


6.2.            They will all require a simple means of demonstrating or having communicated to them that the schemes they are involved with are net zero at the point of practical completion, and net zero enabled for future occupation.




7.1.            Whole Life Cycle Carbon. Operational Carbon Emissions are currently dealt with via Building Regulations and Minimum Energy Efficiency Standards introduced by the 2011 Energy Act among other things. There is currently no legislation or standard practice that addresses upfront and life cycle embodied carbon emissions.


7.2.            It is generally accepted that to address this, the construction industry needs to embrace widespread adoption of Whole Life-cycle Carbon (WLC) assessments. Whole life thinking involves considering all life cycle stages of a project, from raw material extraction, product manufacturing, transport and installation on site through to the operation, maintenance and eventual material disposal… It also considers the future potential for recovery, reuse and/or recycling[5].


7.3.            A key objective of this process is the benchmarking of the carbon performance of buildings and construction[6] [7] to enable comparison of carbon performance.


7.4.            Larger developers are already undertaking Whole Life-cycle Carbon (WLC) assessments of their schemes using their own calculation methodologies and offsetting their emissions based on these calculations. While this is encouraging, it is prone to errors and lacks proper credibility as there is no independent assessment of these figures.

7.5.            Industry bodies (most notably RICS) have set out clear directions as to how their members should undertake these calculations, though there is currently no wider regulatory framework or ‘accredited assessor’ process to ensure that the entire industry is building an accurate pool of benchmarks through consistent application of methodologies.




8.1.            Complexities and lack of a level playing field. With several stakeholders wanting to achieve the same end, there is a danger that they may all set their own standards, thereby putting multiple requirements onto developers for them to publicise the same thing - i.e. demonstrate that they have considered and mitigated the carbon emissions from their schemes.


8.2.            Financial institutions, local authorities and consumers will become increasingly wary of figures produced  internally by developers (or anyone else undertaking construction work). This would be seen as them ‘marking their own homework’.


8.3.            A fundamental part of driving down carbon emissions will be the benchmarking of projects’ carbon performance to enable the grading of projects. Without a standard assessment process the benchmarking ‘pool’, and therefore associated grades will be worthless.


8.4.            Until a building is commissioned, the benefits of any energy efficiency measures or renewable energy sources during the operational phase of a building are entirely notional. While buildings need to be looked at from a whole life perspective, there needs to be a clear distinction between the upfront emissions from construction, and the wider embodied carbon emissions and operational emissions which can only be accurately assessed on an annual basis based on measured data. 




9.1.            The solution is a requirement for a ‘Whole Life Cycle Carbon Assessment’ of building projects, ensuring that carbon emissions from each stage have been considered and reduced as far as is possible at the design stage.


9.2.            Independent certification confirming emissions from each stage have been measured and offset would provide a solution to the various stakeholders requiring confirmation of, or wishing to publicise their building and associated construction work is net zero.


9.3.            Insisting that assessments are undertaken by an accredited assessor working to standard methodologies would provide each of these stakeholders with reassurance that the ‘carbon score’ the projects achieve can be directly compared with those of their peers and competitors. 

9.4.            Upfront emissions from construction throughout the build and at the point of practical completion should be handled by the parties responsible for that part of the process. 


9.5.            A certification program ensuring the ‘upfront’ emission elements of the assessments are undertaken correctly, offset correctly, and issuing a net zero certificate with a ‘construction carbon score’ would enable anyone undertaking a construction project to confirm that the building is net zero at the point of practical completion, i.e. net zero at the point that the building is passed to an occupier. This would provide the future occupiers with a ‘net zero carbon enabled’ building.


9.6.            The occupier can then elect to assess their annual operational emissions and in use embodied emissions and offset the aggregated carbon emissions annually if required to maintain a net zero status for the building.


9.7.            Carbon emissions come from every single construction project from billion-pound commercial projects to small domestic extensions.  The certification scheme needs to be robust enough to be credible, and simple enough to enable developers, builders, or indeed anyone undertaking a construction project to easily assess and compare carbon emissions, offset those emissions and receive certification that this has been undertaken.




10.1.            Driving more carbon efficient construction.


10.2.            Grading performance. The lower the requirement for offsets to demonstrate net zero status the better the standard. This mechanism will both enable enforcement of carbon emission reductions, and encourage the development of innovative new, low carbon building materials.


10.3.            Planning Conditions. The enforcement of specific measures to reduce embodied carbon emissions from construction will be impossibly complex. Adding a planning condition to a Planning Consent stating the recipient must demonstrate that their scheme is net zero at the point of practical completion would be an easy solution. Gradual enforcement of an ever-stricter carbon score over time will force the adoption of more carbon efficient building materials.


10.4.            Encouraging Competition. When minimum standards are set by legislation, those parties subject to these will endeavour only to meet the minimum standards rather than strive to exceed them. To encourage innovation, make it a competition[8], so as well as enforcement via legislation, the publicising of developments’ carbon scores will encourage competition within the industry. This will in turn drive forward the innovation in construction methods and design that is required to catalyse the construction industry revolution needed for our sustainable future.

10.5.            More credible offsetting. Even with major shifts towards a more carbon efficient construction processes, there will always be residual upfront and in use carbon emissions, so to achieve ‘net zero’ there will always be a place for offsetting[9]. The risks involved when dealing with a delicate market such as that of carbon offsets are widely publicised so for it to be an effective solution it needs to be carried out according to very specific guidelines[10]. The acquisition and holding of offsets by a certification body on behalf of those undertaking construction projects will ensure not only that credible offsets are purchased, but that they are not re-sold in the secondary market.




11.1.            To address carbon emissions from the built environment there needs to be a concerted move towards whole life cycle carbon assessments to inform and encourage more carbon efficient construction and operations.


11.2.            For assessments to take place on a level playing field they need to be carried out by accredited assessors. An accredited assessment training program needs to be implemented to ensure those undertaking the assessments are qualified to do so, and that they use standardised methodologies.


11.3.            Independent certification to demonstrate the net zero status of each stage of a building’s life cycle will provide the various relevant stakeholders with confidence that the ratings they achieve are accurate, and that they can be directly compared with those of their peers and competitors.


11.4.            This would play a key role in aligning the interests of the government, financiers, developers and consumers and provide a mechanism to tackle upfront carbon emissions from the built environment.


11.5.            In order to build a more sustainable construction industry, the key focus needs to be on creating the right levers to encourage innovation, align stakeholder interests, and drive down carbon emissions. We believe that independent certification programmes, addressing each stage of a building’s life cycle, using a network of accredited assessors, provides the mechanism to drive industry wide action now.



Tom Scott & Gilbert Lennox-King, The Construction Carbon Footprint Scheme



Simon Sturgis, Targeting zero

Martyn Reed, Managing Director, Elmhurst Energy

Johanna Jarvinen, Bionova Ltd (OneClick LCA)


May 2021



[1] World GBC, Bringing Embodied Carbon Upfront

[2] Bionova, the Embodied Carbon Review

[3] Stop lending to fossil fuel companies, Barclays told, Charlie Parker in The Times, Monday April 26 2021

[4] Analysts expect as much as $500bn of green bonds in bumper 2021, Billy Nauman in the Financial Time, January 4, 2021

[5] Whole life carbon assessment for the built environment RICS professional statement, UK 1st edition, November 2017

[6] Whole life carbon assessment for the built environment RICS professional statement, UK 1st edition, November 2017

[7] BRE Global Methodology for the Environmental Assessment of Buildings Using EN 15978:2011

[8] Anil Rathi, Harvard Business review, November 2014

[9]  World GBC, Bringing embodied carbon upfront

[10] Oxford University, the Oxford Principles for Net Zero Aligned Carbon Offsetting