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We are passionate about the positive environmental impact we can have on buildings, and we believe that the BRE’s new draft Version 7 tool will be a key instrument in this fight.

The scheme is in its final stages of development, and we are deeply invested in ensuring that this new tool will have the impact it should have on the UK industry.

The new BREEAM MAT 01 credit in the V7 scheme has the greatest potential for impacting embodied carbon in construction in the next couple of years. The true impact of the UK Net Zero Carbon Buildings Standard will not be realized for a few years, and Building Regs Part Z is even further off.

We have a long-standing positive relationship with the BRE. Still, we feel it is necessary to express our concerns about one of its most important credits; the new MAT 01 Credit associated with embodied carbon.

Our concerns are:

To effectively tackle climate change, it is crucial to establish a robust and transparent methodology for the life cycle assessment of built environments. It seems that the BREEAM LCA methodology does not align with the RICS Whole Life Carbon Assessment methodology, so not all materials will be covered. Although the draft BREEAM V7 MAT 01 credit mentions RICS standards, it only addresses naming conventions, not the standard itself. Therefore, we recommend adopting the RICS 2nd Edition methodology as a minimum.

We are concerned that the benchmark targets will be too achievable, and we recommend that benchmarks mirror others used in the industry, such as LETI and RIBA 2030, to force buildings aiming for a BREEAM Outstanding rating to go the extra mile.

Whilst we welcome minimum standards for achieving an overall BREEAM “Excellent” and “Outstanding” rating, the V7 draft does not set specific minimum targets for embodied carbon kgCO2e figures. Therefore, if enough effort is put into other areas, there is a potential that the BREEAM V7 could allow ‘business as usual’ embodied carbon performance projects to achieve BREEAM Excellent and Outstanding ratings. We would like to see target sets, especially for Outstanding projects.

We need more rigorous policing. The BREEAM auditors can review the content, but are not able to assess the quality of the embodied carbon reports being submitted. Therefore, the “Third Party Verifier” should be a qualified individual, similar to the Low Carbon Consultant qualification required to submit EPCs, and should adhere to equally rigorous auditing standards. Currently, companies can self-verify in BREEAM V6, and this will not change in BREEAM V7.

Although we welcome the update to BREEAM V7 and the new MAT 01 credit, for the reasons noted above, we are concerned that a major opportunity for the nation’s fight against climate change is not going to make as big an impact as it could. We have raised these concerns with the BRE directly and hope they will consider them before publishing their final V7 documentation.

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