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Some thoughts on BREEAM at 21

by Mel Starrs on May 12, 2011


So my last post seems to have opened up quite a can of worms! I’m going to concentrate on the BREEAM issues for now (though lots of good points raised in the comments which I am sure we will return to soon).

Before I go any further, can I urge commenters to remember that if you are a BREEAM assessor and you bring the scheme into disrepute, your licence can be suspended (refer to your March 2011 Process Note). Let’s all stick to constructive criticism.

I want to explore how BREEAM has changed over the past 21 years – and what today’s raison d’etre for BREEAM is. BREEAM has evolved over time, from a niche to a widely recognised ‘brand’ – but has its popularity diminished its reputation along the way?

Here’s a cracking observation in the comments of my last post:

 I am coming across increased resistance to using green rating tools on a voluntary basis, as people have become frustrated with their oddities and sometimes seemingly bizzare hoops they require…

…I think as this is coming from some with a demonstrated environmental/sustainability bent, a genuine feeling that these codes and rating tools are not necessarily what we need to be doing to ensure a development is as sustainable as it can be. They can constrain thinking and channel actions into a game of achieving credits rather than looking for the best outcome (which may get no credits).

This is a view I’ve seen time and time again. So why then do green rating systems exist? After all, ‘green’ or ‘sustainable’ is a subjective notion at best, how can we possibly hope to quantify it? Partly, I think, is because it is human nature to measure, to draw boundaries around stuff to make it more manageable and to give us a common language against which we can debate.

So green building rating systems, as I tried to explain in the last post, give the industry a way of expressing the degree of sustainability-ness or improvement over the status-quo. In an ideal world we wouldn’t need them at all. But given that green building ratings systems DO exist, is it then a mistake to mandate their use, in either planning or funding requirements? I would argue yes. By moving from a voluntary standard to a mandatory code, standards need to move slightly downwards, in order that everyone can move up. Moving from innovation to compliance is a retrograde step in my opinion.

I’ve mentioned before that I disagree with BRE’s mission of making sustainable buildings a mass-market. I simply don’t think that every building CAN be sustainable, especially if a holistic view taking into account transport and other economic viability measures is used. I would even go as far as saying that not every building needs to be low carbon (historically significant buildings, for example). Have I taken leave of my senses? Surely if all buildings need to be sustainable, there will be a massive market opening a floodgates of opportunity for sustainability consultants? Not so much. Typically when a system caters to a mass market, it becomes commoditised, losing value. Low value offerings are seldom profitable for anyone.

This is one reason I was not a fan of the requirement for BREEAM within BSF. Prescient, even if I do say so myself, given the conclusions of the Sebastian James Review (pdf, 105 pages). James criticised BREEAM for being prescriptive – para 4.12:

Another example of how bureaucratic this guidance can be is the Building Research Establishment Environmental Assessment Method (BREEAM) which regulates the environmental impact of a building design. All new school designs are expected to achieve a ‘very good’ rating under BREEAM guidance before they can go ahead.

BREEAM has been criticised for being very prescriptive, providing incredibly detailed guidance on matters such as cycling facilities (8 pages long) or of the ecology allowed on site (25 pages long). BREEAM has been revised for 2011 to consolidate criteria and reduce the bureaucracy, detail, and complexity required, which represents a good start. The transport criteria – including cycling facilities – have been consolidated, and a number of compliance notes have been removed. However there are still too many detailed areas with which schools must comply in order to reach the required standard.

And then para 3.18 in the conclusions:

Whilst the current move to simplify BREEAM should be welcomed, it could go further, and the expectation that it should be used at all times does not allow for Local Authorities to best determine the tools that they should use to ensure sustainable buildings.

Ouch. I fully expected to see BREEAM being dropped entirely as a requirement after such criticism, but James seems to recognise some benefit in keeping it:

Recommendation: That the Department revises its school premises regulations and guidance to remove unnecessary burdens and ensure that a single, clear set of regulations apply to all schools. The Department should also seek to further reduce the bureaucracy and prescription surrounding BREEAM assessments.

Gordon Hudson on Twitter at the time the review came out mused that this may indicate a move to something akin to NEAT, the self-assessment tool previously used in Healthcare (replaced in July 2008 with BREEAM Healthcare). A kind of BREEAM lite. My question would be – is there value in BREEAM remaining associated with a watered down version or should something completely new divorced from the brand be created?

The criticism of jumping through hoops and being over prescriptive in part comes from BREEAM’s success too. I fondly remember the days when the BREEAM assessor was able to use judgement and their understanding of the project when awarding credits. There was a certain level of discretion available to the assessor. Those days are gone, as anyone who has gone through the BREEAM QA process recently can atest. Items of evidence have to be submitted in exactly the correct way or they will be rejected. I have concluded that in order to process the volume of information at a reasonable cost, BREEAM have had to ‘standardise’ evidence requirements. Personally, I’d be happier asking the client to pay a bit more and having some discretion back. As I’ve said before, when things are commoditised, they tend to lose value…

I’m scarcely an independent observer on this topic – a significant proportion of the current income of my department depends on the continued use of accreditation systems. That said, I happen to find buildings with ambitious sustainability aspirations a lot more fulfilling to work on than buildings which are chasing a certificate for the sake of compliance (well really, who wouldn’t?). And I have already conceded that not all buildings are going to be truly sustainable. So have green building ratings systems evolved past their usefulness at the top end of the market? Should they now be mass market, fulfilling the needs of the majority? I struggle to see where the value in this is? If everyone’s doing it, eventually it becomes obsolete. The value surely lies in being an indicator of differentiation.

I would love to be writing at BREEAM at 30 post in 9 years time. I think the likelihood of that depends on what the next reincarnation of BREEAM turns out to be. There will no doubt be those who see no value at all in continuing with green building rating systems. Others will want the entire industry to use BREEAM. Personally, I want to see a return to the high end of the market with a mechanism for rewarding innovation and a move away from strict compliance to minute inconsequential details. The value lies in a client being able to boast meaningfully about their green credentials using language and metrics which have a shared understanding with others in the industry.

Comments (as always) welcome…

  • @tokaino

    “I simply don’t think that every building CAN be sustainable, especially if a holistic view taking into account transport and other economic viability measures is used.”

    Your last two posts are welcome in an increasingly necessary dialogue. However, I think such discussions need to be in three parts:

    a. Sustainability and green rating schemes (LEED, BREEAM etc) – which deal with the ‘environmental’ perspective including transport, water use, views out… and consider the impact of a project on its location and resources – are voluntary in most cases. *Volunteering* to go further than Joe Bloggs is the foundation of any ‘environmental’ concerns of the last 20 years. As you said in June, “in my opinion there will always be a space for a voluntary scheme which rewards those who do more than the statutory minimum.”

    b. Carbon Emissions - despite becoming the way much of the industry thinks about sustainability, that really isn’t the case – I’m particularly thinking of Criterion 1 in AD L being the only mandatory element representing Part L, the rest is open to interpretation and the ADs guidance. However, as you’ve said yourself, SAP and SBEM were never designed to be anything more than compliance checks. Sustainability, and even energy performance, is about rather more than CO2.
    I think FEES will become mandatory in 2013, but we’ll see housebuilders doing the bare minimum to comply. True ZC and CSH6 will demonstrate rare, exemplar buildings. You only need to look at the amount of applications LABC received when the 2010 transition period was announced to allow work to 2006 regs. A client who can volunteer to push the boundaries is a rich client.

    c. Building Regs as a whole - Scotland is aiming to be far better than England, Wales for even stricter regs altogether. Devolution (of regs) means that instead of a universal building code and a collaborative aim for the UK to save energy, we’re going to end up with four competitors in a race, all running different distances. I know where I’d choose to build houses. That’s a completely separate issue.

    I’m currently writing an epic article on this. I’ll be sure to cite you as ever ^_^.


  • Kevin Couling

    Great post Mel.
    I’m not sure where to start with BREEAM if I’m honest, Thoughts are
    likely to be fairly incoherent but nonetheless here they are…
    The BRE have done a great job with BREEAM, assuming (and I take it
    from you saying “BRE’s mission of making sustainable buildings a
    mass-market.” that this is the case) the intention was to create a
    product with the highest possible market penetration.
    That, to my mind, is one of BREEAMs greatest successes – that it has
    achieved the market penetration it was aiming for and in so doing it
    has, if nothing else, ensured that there is a heading related to
    sustainability on the agenda of very many construction
    projects in England & Wales (I can’t speak about Scotland or
    Northern Ireland as I have no experience – anyone?).
    Now, I’m not sure I’ve ever really experienced this (I became an
    assessor in something like 2004, so a relative newbie) but I presume
    there was a time when a client carrying out an assessment was doing so
    because the scheme (and the assessor) provided
    what they considered valuable guidance and offered the building a way of
    differentiating itself from other, less sustainable, contemporaries.
    However, the outcome of such a pointed and successful focus on
    market penetration is that it seems the delivery of BREEAM is now
    undertaken because clients have to rather than want to – I’m not sure
    we’ll ever know whether mandatory compliance was an intended
    endgame or not, but it doesn’t really matter because the outcome is the
    same. You don’t have to spend too long in silent meditation to realise
    that as many projects are only doing it because they are mandated to,
    they’re only doing as much as is absolutely
    necessary to achieve the rating they require. That’s not necessarily a
    failing of the scheme in itself but more a function of its fairly
    sweeping application by funders, planning bodies and so on.
    So, whilst the greatest success of BREEAM is its near universal
    adoption by planners etc, its greatest shortcoming is that, as a
    consequence of its success, its effectiveness has been diluted.
    I anticipate that the above is a fair summary of what lots of
    people think about BREEAM (somewhat more politely expressed than I’ve
    heard in the past incidentally), but I want to throw in another thought…
    I guess there are still clients out there who are doing BREEAM
    because they actually do want to, irrespective of planning conditions – I
    guess these are the assessments that are now achieving Outstanding
    ratings. So, is it such a bad thing that the people
    who still want to differentiate their buildings can and are doing so by
    achieving an even higher standard and those that, before BREEAMs
    undeniable success (in the terms I mention above) wouldn’t have
    bothered, now have to at least do something? For me, the
    answer to that isn’t a straight yes or no. It sort of depends on your
    perspective – I mean, if you sell leak detection systems then, yep, but
    if you are trying to get the project to respond sustainably to local
    biodiversity in the urban built environment, maybe
    not – to give two quick examples.
    I’ll leave everyone else to decide where it’s a good outcome and
    where it means people do what they have to in order to get the credit
    rather than what’s right for the project and how those two things
    balance out.
    Your observation on assessors no longer being able to exercise the
    discretion and judgement at one time at their disposal is well made.
    They are typically between the proverbial rock and the deep blue hard
    thingy…they’ve got no way of forcing people to
    provide evidence at all and they’re also not able to make a judgement
    about whatever they do receive. The problem being that because clients
    are doing it because they have to, the BREEAM assessor is rarely seen as
    a valuable member of the project team. In fact
    they often see you more like their hairy old Aunt Muriel, who they know
    they’re going to have to kiss at some point, but keep putting it off
    until when they do finally get round to it, it’s so half-arsed they may
    as well have given you a crappy photo of Mick
    Jagger – all about the lips, but not really what you were after.
    So, anyway, about the scheme itself, I can be brief here because
    it’s summed up pretty easily really; I think BREEAM doesn’t do so well
    on the stuff which relies for success on the ongoing engagement and
    interaction of the users with the building or its
    grounds (eg carbon, ecology). I also think it’s actually pretty good at
    anything which doesn’t rely on that interaction (eg materials). Again,
    I’ll leave you to decide which specific issues are which.
    Well, I’ve taken enough of your time good people and anyway I’m
    still pondering the question of whether all buildings can be

  • Mark Boot

    Why not abolish BREEAM altogether and upgrade Building Regulations?? My experience from working on a project in South Wales where a BREEAM rating of “very good” and energy level “excellent” is stipulated is that very few understand the requirements including Planning, Client/Funder, etc etc. The BREEAM assessor we appointed hasn’t really assisted us in the process whatsoever and we’ve also struggled to achieve credits due to the building having two forms of calculations (SAPS and SBEM). We also had a relaxation on the energy rating as it was established that “excellent” couldn’t be achieved!  we’ve also now been informed that the BRE are struggling to process certificates quoting 2/3 months in lieu of 2 weeks!