Communities and Local Government CommitteeWritten evidence from BRE Global


We welcome the aim of the draft NPPF to provide a relatively short, clear statement of Government policy, while recognising the complexity of applying the principles of sustainable development in practice.

Sustainable construction is of major significance to the UK economy as well as to the Government’s aspiration to be “the greenest government ever”.

Schemes such as the Code for Sustainable Homes and BREEAM (BRE Environmental Assessment Method) provide a way of addressing sustainable development issues holistically. Reference to a national framework for the setting and evaluation of sustainability standards would provide consistency for the construction industry and avoid confusion, while allowing local planning authorities discretion in how to apply such standards in their areas.

BRE Global would be happy to help with drafting good practice guidance on the implementation of sustainable construction policies and practice in the planning system.


1. BRE Global manages the implementation of the Code for Sustainable Homes under contract to the Department for Communities and Local Government. It is also responsible for the BREEAM (Building Research Establishment Environmental Assessment Method) family of schemes. BREEAM is the longest established and most widely used methodology in the world for assessing the environmental performance of buildings.

2. BRE Global is one of the BRE Trust group of companies with a history stretching back over ninety years. It was formed following the privatisation of the Building Research Establishment which had been part of government.

3. The constituent companies within the group gift aid their profits to the BRE Trust (a registered charity) to undertake research and education for the benefit of the built environment.

4. As an example of the value of sustainable construction to the UK, BRE Ltd has recently signed a contract to develop an innovation park in China which is worth up to £100 million to UK industry. It has also recently signed an accord with the Brazilian Ministry of Science and Technology to collaborate on Brasilia Innovation Park.

5. Many leading organisations in both the public and private sectors require BREEAM assessment of their buildings as a matter of policy because it provides a comprehensive and cost-effective way of improving both environmental and economic performance. The Government includes a requirement for all buildings in its estate to undergo assessment as an integral part of its drive to reduce carbon emissions and improve sustainability.

6. BRE Global thus occupies a unique position, as part of the de facto centre of excellence for the built environment and in terms of its track record and expertise in promoting sustainability. In particular, the Code for Sustainable Homes and BREEAM have achieved national and international recognition as the leading assessment methodologies in their field.

7. Our evidence relates primarily to a) the importance of sustainable construction to both the UK economy as a whole and to the Government’s policies on sustainable development, climate change and carbon emissions and b) the role that policies on sustainable construction can play in the planning system. Where appropriate we have tried to relate this evidence to the specific questions that the Committee has posed.

Is the definition of “sustainable development” contained in the document appropriate; and is the presumption in favour of sustainable development a balanced and workable approach?

Is the relationship between the NPPF and other national statements of planning-related policy sufficiently clear? Does the NPPF serve to integrate national planning policy across Government Departments?

Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, while at the same time giving local communities sufficient power over planning decisions?

8. These three questions are closely inter-related. We have started by looking at the definition of sustainable development, as much else in the NPPF flows from this, along with the “presumption in favour of sustainable development”. We have then considered how the NPPF relates to other aspects of Government policy, before finally looking at the implications for local planning authorities, the Planning Inspectorate, developers, investors, and local communities.

9. We consider that the draft NPPF’s use of the Brundtland definition of sustainable development is a good starting point. As the Stern Report and others have made clear, two of the key features of sustainable development are a proper consideration of externalities (such as global warming or the depletion of non-renewable resources), and the need to consider long-term time horizons.

10. We consider that the draft NPPF could usefully refer to the economic importance of a low carbon economy in the economic section, as well as reflecting its environmental importance towards the end of the document. This could help it to align more clearly with Government policy elsewhere, for example in the Coalition Agreement, where the Prime Minister and Deputy PM state “we both want to build a new economy from the rubble of the old. We will support sustainable growth and enterprise, balanced across all regions and all industries, and promote the green industries that are so essential for our future”.

11. The Business Secretary added his weight to the economic importance of green businesses on 4 August: “The transition to a green economy presents significant growth opportunities both in the UK and abroad. The UK has the sixth largest low carbon economic goods and services market in the world.” [Department for Business Innovation and Skills press release, 4 August, 2011].

12. On 5 August 2011 the Government published “Encouraging the transition to a green economy: Government and Businesses working together”, ( which sets out further details of this agenda. Publishing the document, the Secretary of State for Environment, Food and Rural Affairs said: “Moving to a green economy presents huge opportunities for British businesses not only to reduce their environmental impact, but also to transform products and services, develop cleaner technologies, and capture new international markets.”

13. This is particularly important in relation to sustainable construction. Assessment methodologies such as BREEAM play a very significant role in enabling UK businesses to generate export opportunities. The UK is viewed internationally as a beacon of best practice in securing a low carbon, highly sustainable built environment through good science. BREEAM, as the most widely used assessment methodology in the world, plays an important role in this, and has recently been described by the chief executive of the British Property Federation as a “British success story” [Delta T Magazine, January 2011]. Indeed, such are the skills of UK designers that their output is the second largest “invisible” export after financial services. The UK Low Carbon Environmental Goods and Services Market is the sixth largest in the world and grew by 4.3% in 2009. It is now worth £112 billion, employing over 900,000 people. The UK leads on sustainable construction, with UK architecture and engineering firms creating and designing for sustainable cities across Asia and the Middle East. [UKTI]. UK businesses and investors have made substantial commitments to sustainable construction, and it is important that the NPPF does everything possible to ensure continuing confidence in this vital sector.

14. The Government’s Carbon Plan published in March this year states at para 3.12: “The Government wants to support and enable communities in their wish to adopt higher environmental standards for new homes including through: ensuring that there are robust sustainability standards for local authorities to use if they want to set higher standards than those in the national regulations in their local plans. For example, the Code for Sustainable Homes provides standards for the sustainable design and construction of new homes (including water efficiency) that meet or exceed those set out in The Building Regulations 2010; and supporting eco-towns and ecodevelopments where there is local support and a wish to adopt higher standards of sustainability and design.” As the planning system is the route by which this would be achieved it would be helpful for this to be made explicit in the NPPF.

15. The Code for Sustainable Homes is one of the key tools in the Government’s armoury for driving up standards in the housing sector, and thereby driving innovation and change within the construction industry. This in turn helps to create the new jobs and opportunities that are key to the success of the “green industries” integral to the Government’s vision of the future. BREEAM plays a similar role in the non-domestic sector. Both the Code and BREEAM are voluntary schemes, which a large number of local planning authorities have chosen to incorporate within their local plans/local development frameworks.

16. The sustainable construction industry is thus hugely important to the UK economy, and BREEAM and the Code for Sustainable Homes play a leading role in driving change and innovation within it. One of the main ways of supporting this work is through the planning system. We consider it would thus be helpful for the NPPF to give a clear indication of the Government’s commitment to the use of assessment methodologies such as BREEAM and the Code within the planning system.

17. Assessment methodologies such as BREEAM and the Code are designed to address a raft of environmental and sustainability issues in a holistic way, including all of those set out in the section on “Planning for places”. The Code for Sustainable Homes, for example, covers the following: energy and carbon dioxide emissions, water, materials, surface water run-off, waste, pollution, health and well-being, management, and ecology.

18. They can be powerful aids to achieving improved outcomes in the built environment. However, it is important that a) they are seen as integral to the development process and b) that they are incorporated at the earliest possible stage. In this context, it might be helpful for the statement (para 58) that “Consents relating to how a development is built or operated can be dealt with at a later stage” to be amended so as maximise the opportunity to incorporate improvements at an early stage where it is both easiest operationally and likely to involve minimal or no additional cost.

19. In order to ensure that the NPPF is well aligned with the Carbon Plan and to provide clarity for users of the system, it might be helpful for the NPPF to make clear that in principle it supports the incorporation of measures such as the Code for Sustainable Homes and BREEAM within local plan policies as an important component of local choice. In order to adopt such policies, local planning authorities should be required to provide evidence in preparing their local plans a) that the policies were locally appropriate and b) would not, of themselves, unreasonably affect viability (recognising that there will be occasions, such as during financial crises, when no amount of amendment of the planning system will affect the viability of development).

20. Once sustainable construction policies were established in an adopted local plan, the onus should then be on the developer to provide evidence in particular cases if they considered that the development would not be viable.

Are the “core planning principles” clearly and appropriately expressed?

21. The core planning principles are set out in paragraph 19 of the draft NPPF.

22. Perhaps the most striking point about the core planning principles is that the last seven of the ten are explicitly addressed by BREEAM and six by the Code for Sustainable Homes (the Code differs from BREEAM in not including transport as one of its issues). The impact assessment accompanying the NPPF recognises the importance of many of these issues, stating, at p 68, “There are however opportunities through the planning system to ensure that the new housing incorporates sustainable design and renewable energy, for example through rain water harvesting, maximising solar gain and use of photovoltaics, and ground source heating.”

23. The NPPF could therefore provide a powerful message of support for these core principles by specifically endorsing assessment methodologies such as BREEAM and the Code. It would then be up to local planning authorities, in line with the spirit of localism, to adopt these and indicate the level of performance they seek as appropriate to their local circumstances. Building on the already widespread use and acceptance of these methodologies, this would provide developers with a well understood framework which will allow them to demonstrate sustainability without extended confusion and debate.

24. Should the Government consider that there was a need for further informal good practice advice on the appropriate use of such policies and standards, BRE Global would be happy to assist in this.

Does the NPPF, together with the “duty to cooperate”, provide a sufficient basis for larger-than-local strategic planning?

25. It will be important for the NPPF to provide the guidance needed to secure the most sustainable outcome in circumstances where larger-than-local issues are involved eg where the renewable energy source to serve a new development would be best located in a neighbouring local planning authority.

Are the policies contained in the NPPF sufficiently evidence-based?

26. It would be helpful to provide evidence on the importance of sustainable construction to the UK economy. For example, the Low Carbon Construction Innovation and Growth Team final report highlighted both the wider green economy benefits and the fact that transforming the built environment to low carbon could provide the industry with a 40 year programme of work and act as a springboard to growth for more than 200,000 small businesses in the sector.

This is relevant to the Government’s objective of achieving a sustainable built environment through the planning system. As we have set out above, setting challenging standards for construction is good for the environment and good for the UK economy, as well as being entirely in line with the Government’s “intention to become “the greenest government ever”” (NPPF Consultation, para 32).

The fitness for purpose of the draft Framework as a whole

27. The aim of the draft NPPF to reduce the length and complexity of existing planning policy documentation is to be welcomed.

28. There are some areas, particularly in relation to sustainable construction, where as indicated before amendments to the NPPF might usefully provide greater clarity. In addition, there may be value in some further good practice advice on this subject, which we would be happy to help to prepare.

19 August 2011

Prepared 20th December 2011