Environmental Assessment of Buildings and Building Developments
- a logical methodology for the world.

1 INTRODUCTION

At the present time there are no plans to require formal environmental assessment of new buildings. Consequently, there has been little scrutiny of the criteria for assessment compared to those used for Environmental Impact Statements (often known simply as Environmental Statements). These are now required to be published within many Member States of the EC for major civil engineering projects such as new motorways, power stations and airports. Hundreds are summarised in the Directory of Environmental Statements (1). Formal assessment procedures have developed differently around the world but the two principal legislative influences have been the National Environmental Policy Act of 1969 in the USA (2) and the EC Directive of 1985 (3).

The rationale behind most environmental impact assessment (EIA or just EA, environmental assessment) has been to influence developments at an early planning stage and to raise the profile of environmental concerns throughout the planning process. Whilst a few formal environmental assessments have led to schemes being abandoned, the more usual outcome is for changes to be made and without undue costs. Also, it has been usual for Environmental Statements to be used to justify a project as far as is possible, rather than to present an impartial perspective and to suggest alternatives.

It was partly in response to the variable quality of Environmental Statements in the UK that the Institute of Environmental Assessment was formed in 1990. In the USA, where there is more public familiarity with the processes of litigation, environmental groups have used the Courts extensively to ensure enforcement of EIA procedures (4). In many countries however, neither EIA procedures nor ready access to enforcement exist.

The stated aims of EIA include ensuring that the likely effects of a new development are fully understood and taken into account in proposals: for example, whether altering the course of a river would adversely affect bird populations and nesting sites or whether a new road scheme would adversely affect too many houses. Effects on the cultural heritage are also included in the EC Directive, from which stems British legislation and Government guidelines.

Inevitably, the need for formal Statements has opened up decision-making to public scrutiny, and it continues to be recognised that the success of the whole EIA process depends, inter alia, on the quality and independence of Assessments and Statements. Five years after the Environmental Assessment Regulations came into operation in the UK many Statements are still of poor quality. The UK government has been accused of failing to provide adequate guidance on appropriate format or structure (5) and of failing to establish effective quality control (4).

The earliest attempt to produce an assessment methodology specifically for buildings was published in 1990 as BREEAM 1/90 by the Building Research Establishment (6). Other editions have since appeared and are reviewed in Section 4.

The present methodology was developed in response to requests for an alternative to BREEAM that could take into account all of the major environmental impacts of buildings. It has the advantage of a logical framework suitable for application to all building types and developments, and in all countries. Also, it seeks to put primary environmental concerns first, irrespective of whether they are linked to parochial research fields such as buildings' energy use.

It is inherent in the present methodology that the scope of each assessment must be considered in the context of the particular building development, since one or a few factors may be of particular environmental concern. In contrast, BREEAM has remained essentially a point scoring approach capable of awarding high marks to damaging developments, and vice versa. Recognition of the importance of scoping (to use the jargon of EIA) has been a major factor in the development of the basis for mainstream assessments in the UK over the past three years.

In summary, EIA must still rank as a new and evolving discipline despite a 25-year history in the USA and over a decade of discussion in the UK. It developed primarily as a focus for growing public concern for the environment but to date has been applied almost exclusively to single projects. In the last few years EIA has been applied at a strategic level in some countries and to help evaluate radical and alternative proposals, including what the Council for the Protection of Rural England (CPRE) has called the zero option - abandoning a project entirely because of its adverse environmental impact (7).

If many environmental trends are not halted or reversed the epitaph of EIA may be that it became an ineffective self-serving bureaucracy. It is too early to pass judgement, especially in respect of the enormous role that EIA should play in the developing world and in the reconstruction of Eastern Europe. However, it would be useful for targets to be set in key areas, and for progress to be monitored.

The greatest danger for EIA is that it may become even more of a routine paper-generating and presentational activity and with little real impact on determining the magnitude of total environmental degradation. The test must be one of effectiveness and achievement.

1.1 History of environmental awareness

Environmental issues have been of wide public concern only in the last three decades. Consciousness was awakened in 1963 by Rachel Carson's book "Silent Spring" (8). Thirty years later, environmental assessment, regulation and control have grown into a multi-billion dollar industry. Despite this, destruction of the natural environment is continuing, and with the pace quickening in many countries.

In contrast to much of Europe, the UK has been noted especially for concern over many wildlife issues, but has been criticised internationally (and sometimes unfairly) in respect of its stance over energy use and waste disposal. Inevitably there are different perspectives in different cultures, but a broad consensus is continuing to develop on primary environmental issues. These are defined as issues that, if neglected or adversely affected by a development could result in irreversible damage to the wider environment, or in more colloquial terms to Life on Earth. This is further explained in Section 2.

Recognition that urban environments could be unhealthy, preceded the contemporary environmental movement. In the UK, London smogs of the 1950s killed thousands, but so well characterised was the problem that simple legislation restricting the types of fuel able to be used for home heating proved an adequate response, until the advent of the mass use of cars. Another legislative/technical fix - the three way catalyst - is still promoted as the solution to this latest form of inner city pollution, but is known not to be wholly effective because of poor performance during the warm-up phase and increased fuel use.

The questioning approach that has been adopted to this 'green' technology is an example of how solutions are now examined for spin-off consequences, and especially by environmental groups. For example, tall chimneys in the UK have been blamed for transporting sulphur dioxide to Scandinavia and three way catalysts for increasing fuel use and thus contributing to both reserve depletion and global warming. Processes for scrubbing sulphur dioxide from power station chimneys can generate huge amounts of solid waste, as well as requiring limestone to be quarried from the countryside.

Slowly, it is becoming accepted that there may be few easy solutions, and that limitation of both population and primary consumption may be necessary - ideas widely dismissed as heretical in the 1970s. For more than two decades environmental groups have berated governments for perceived inaction or inadequate responses to environmental problems, whether real or largely imagined. Buildings' environmental assessment, a latecomer in the totality of environmental awareness, must therefore be developed in a climate of rigorous analysis.

Spectacular growth of environmental consciousness has been matched (at least in the West) by commensurate funding. It would be surprising if this had been without controversy. In the USA there have been severe criticisms of programme management, particularly involving the Environmental Protection Agency (EPA).

EPA's problems are rooted in a culture that applauds heroic and high-profile actions, rather than measured and calculated responses. Perhaps as a consequence, resources have not been directed at problems in proportion to their potential importance, issues have been misclassified and handled by inappropriate Departments of Government, and budgets have become the playthings of special interest groups within or close to Government at both a Federal and State level (9), (10).

In the UK, a climate of secrecy has continued to prevail within Government Departments. The opposite is aspired to in the USA with its Freedom of Information Act. However, in both countries logical examination of problems and utilisation of the best scientific consensus may be undertaken either during or after the bulk of programme expenditure, and not as a part of initial or ongoing policy formulation. Again, high profile heroics and political expediency can be partly to blame, with the Star Wars programme being probably the best example of expenditure irrespective of scientific credibility.

In the field of building, the asbestos removal programme in the USA is now credited with the poor deployment of probably $40 billion. The UK response to asbestos was more logical. In both countries however, responses to nuclear waste and disposal problems have been extreme and with an almost total failure to communicate risks and to argue for rational expenditure. Thus, probably billions of dollars will be spent on containment of material that could safely be dumped in ordinary land-fill sites whilst countless thousands of people will continue to become incapacitated or die prematurely for the want of a few dollars of health care. Similar disparities are emerging in developing countries.

For years the issues have been available for scrutiny, but such has been the apparent willingness of the nuclear industry, for example, to spend excessive amounts on safety that rational analysis has been kept largely out of the public debate. Specialist analysis has however been available (11) and the scientific Press contains regular exhortations to common sense. For example, a letter to the science journal Nature comprises a blunt denunciation of the incompetence of politicians when dealing with matters they obviously do not understand.

"Our striving for a riskless society, coupled with political manoeuvring and a misinformed public, can lead us to heights of absurdity that would be funny were it not for the serious consequences in terms of cost, loss of productivity and misdirected effort." (12)

The letter was written in 1990, but could just as easily have been written in 1993, so pitiful has been the progress towards common sense in prioritising expenditure on measures to reduce risk.

Overall, there has been a lack of logical programme objectives, insufficient peer involvement, and no effective accountability of programme administrators. Within EPA, cultures developed in which myths became self-reinforcing core beliefs because of lack of effective external policy review.

These observations are important because of the extent to which EPA is seen as a model for other countries. The problems are discussed in several published papers, for example (13) (14), (15), and (16) in which aspects of the EPA radon programme are examined.

Radon is probably the most contentious of the EPA's present programmes because of the highly personalised nature of the disputes, but other examples may be quoted showing misdirection of concerns, programmes and projects, and not only in the USA:

• New packaging and waste disposal laws in Germany may, at the margins at least, result in greater environmental impact in their application than would have resulted from conventional waste disposal. The central fact to be acknowledged is that an industrial society must produce some waste and must consume some resources irreversibly.

Also, it can be both uneconomic and environmentally inefficient to attempt to recycle everything. The logical absurdity may be demonstrated by driving around a city to collect discarded paper-clips. Nevertheless, the German system has resulted in questioning of the need for packaging, and some has been abandoned. Thus, total avoidance of primary consumption has resulted from a recycling initiative.

• Extreme standards are being implemented in respect of water quality (to quote one of several examples from the UK) but based more on ability to apply technology regardless of cost than on proven disbenefits of marginal pollution, and

• Attention is being directed too much towards convenience projects such as recycling instead of addressing the more fundamental (and politically uncomfortable) issues of limiting population and primary consumption.

These diverse examples illustrate fundamental weaknesses in environmental policy -

• failure to categorise issues logically,

• failure to encourage the public to think logically, and

• failure to ensure allocation of funding to achieve maximum environmental, health or business benefits.

In the simplest terms, massive effort is being devoted to issues that may be calculated to be of little concern whilst primary environmental problems remain unresolved. Buildings' environmental assessment must seek to avoid this weakness.

Against this general logic, some environmentalists argue for the precautionary principle - to assume that harm will be caused until it may be proven otherwise. Whilst this may be agreed as wise if the issue is one potentially affecting primary environmental issues, the concept has little validity for secondary or health issues. Indeed, it is an interesting exercise - not pursued here - to apply the precautionary principle to mainstream health care.

Within the wider generality of environmental assessment, central criticisms of methodologies have included - 

• failure to outline objectives,

• failure to develop strategies based on objectives, and

• failure to develop projects within a programme formulated to achieve defined strategic aims.

Most assessments have been entirely project-based, with no perspective for wider implications and no appreciation of linking with other, geographically adjacent projects. This may be viewed as a hangover from the days of one-problem one-solution.

The leading countries in development of well-thought-through objectives and strategies are perhaps the Netherlands and the USA. These countries are also known for their degree of open government. A published summary of the central arguments for strategic environmental assessment is available (17). A major initiative in the Netherlands has been the development of a methodology for measuring sustainable national income, as opposed to the traditional Gross Domestic Product (GNP) (18).

Calculation of the monetary worth of the environment is now widely seen as essential for environmental science generally and for rational application of environmental assessment methodologies. Nevertheless, the danger that environmentalists could be seduced by a narrow resource rationale for conservation was highlighted over a decade ago (19).

Environmental concerns derive often from perceived risk, whether to the environment or to human health, and problems of risk communication underlie concern over assessment methodologies. Central to the development of inadequate environmental policies has been a conspicuous lack of understanding of risk by both the public and politicians. Scientists have criticised "the waste of public effort on trivia" and the propensity of the media to seek out "a good story" irrespective of proper perspective. A review of risk analysis and management has recently been published (16). It claims that entrusting policy to panels of experts behind closed doors has proved a failure and that many officials have far too narrow an outlook on the risks they manage.

Another characteristic is most apparent in the USA, but shows danger of spreading. This is for vastly more resources to be devoted to apportioning blame and to litigation than to resolution of the environmental problem, if indeed there is found to be a problem once the fog of law has cleared (21).

Key points may thus be identified: 

• contemporary environmental awareness stems from the mid 1960s and originated in concern about wildlife and habitats. Later, energy use became a dominant issue but progress towards decreasing overall world consumption has been patchy.

• widespread recognition of the importance of primary environmental problems has been a recent development. Issues include energy consumption, use of ozone depleting chemicals and maintenance of species diversity, especially in tropical forests. All of these impact directly on buildings' environmental assessment.

• proposing simplistic solutions for environmental problems is no longer tenable unless confirmed by detailed analysis. Life-cycle analysis has become popular, but is applied more to discrete materials and manufactured goods than to whole systems or buildings. Nevertheless it may play a part in buildings' assessment.

• early environmental assessment has been criticised for its piecemeal approach and for failing to recognise wider contexts. Thus, building developments or road construction could proceed 'little by little' without any assessment highlighting the likely total consequence of many small projects.

• publication of new guidelines for strategic overview should help prevent inadequate project-only assessments. The implications for buildings' assessment include that primary environmental issues must be addressed irrespective of the perhaps small impact of an individual development, and that assessment must begin at the site selection stage.

• officials and the public continue to display confusion over risk assessment and evaluation. Major efforts may be necessary to encourage concern over impacts on primary environmental issues, and to allay fears over issues seen as major but whose potential impact is either small or localised. Buildings' environmental assessment has a role to play here.

• converting all environmental concerns to a common monetary base has been advocated for over a decade as an attractive way of enabling conventional economic calculations to be applied to environmental problems. Whilst the idea has some merit scientists have warned that it should only ever be viewed as an aid to decision-making.

1.2 Buildings' assessment

Acknowledgement of the inadequacy of much early environmental analysis forms a backdrop to discussing buildings' environmental assessment. It is also useful to discuss energy use in some detail.

For decades, and especially since the energy crisis of 1974, energy use within buildings in the West has been the focus of major publicity and research efforts. Analysis has accomplished much understanding of building design and peoples' interactions with building fabric and control systems - and major reductions in energy consumption have proven feasible.

Political influences in energy research and application were evident from an early stage. Initially, the work was called energy conservation. Later, when conservation became too much identified with zero-growth philosophies, the alternative of energy efficiency was preferred. More recently still, carbon dioxide emissions have become fashionable as the unit of concern, but sometimes without due recognition of the benefits of nuclear generated electricity, an important point for design and assessment of buildings.

However, despite changes of title the underlying building physics has remained much as before. Even for the simplest of buildings (houses) technical interactions and economic trade-offs concerning energy use are commonplace. For example, higher standards of insulation can increase the risk of interstitial condensation and structural damage. Also, energy saving from more sophisticated control systems can be so small in very well insulated buildings that a simple time-switch may be adequate, especially when life cycle costs are considered.

Many early designs of low energy houses in Europe and the USA owed more to enthusiastic use of novel technology than to serious consideration of how to design low energy mass housing utilising a minimum of all raw materials over the design lifetime. A notable weakness of many energy demonstration projects was the inadequacy of (or often a total lack of) monitoring to assess whether design aspirations had been realised in practice, and maintained after decades of use.

Thus, the saga of low energy projects in the 1970s and 1980s serves as a warning for buildings' environmental assessment which of necessity must deal with issues more complex than energy use. There needs to be a good understanding of fundamental issues and rationale, and no amount of glossy literature can ultimately disguise expediency.

At a practical level, achieving energy conservation was hampered by the benefits of improved efficiency in fuel use being taken wholly or partly as increased thermal comfort (higher indoor temperatures in wintertime or increased use of air-conditioning) and by any move towards reductions in indoor environmental standards being thought sacrilegious. The result has been that building energy use has slowed its rate of increase and has reduced slightly in some sectors and in some countries, but the massive reductions known to be possible have not materialised.

Given that for more than three decades one of the principal impediments to adoption of energy conservation has been the low price of fuel, with petrol still being cheaper than milk, it has not helped that some fuel prices have decreased in real terms. A more insidious problem, never these days discussed in official energy efficiency literature, is the marginal propensity to consume - a saving of energy (and the cost thereof) in a building being used for some other purpose that itself consumes energy (21) (22).

There is another warning here for buildings' environmental assessment - genuine achievement may remain small in the absence of compulsion, and despite decades of exhortation.

Energy use continues to be acknowledged as a key issue of building environment, and it is likely that any assessment method would have energy as one of its core concerns. Nevertheless, and despite the pivotal role that building designers and planners will continue to play in determining national environmental performance, it needs to be understood that any methodology of environmental assessment should start with THE ENVIRONMENT as the principal concern, and with energy use finding its place within a framework dedicated to environment in its widest sense.

Herein lies one of the central weaknesses of BREEAM, an assessment methodology first published only for new offices (6). Later versions addressed other building types. The scheme has been criticised for its lack of intellectual rigour and in publicity material has been hyped out of proportion to content and likely applicability. This occurred primarily because no competing methodology was available and because funding was made available to projects aimed at greening the official image in the run-up to the 1990 White Paper on the Environment (23).

In essence, BREEAM was developed by an organisation steeped in buildings energy analysis, but having no history of concern for wider environmental issues. It is further discussed in Section 4, and whilst it might be thought unnecessary to dwell on inadequacies, the lessons are central to development of a logical methodology, and hence to assessments that should survive analysis.


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