2 A LOGICAL BASIS FOR BUILDINGS' ENVIRONMENTAL ASSESSMENT

2.1 Classification of issues

The central importance of correct classification within environmental assessment is that this process may determine levels of concern, funding and action. Environmental assessment needs guidelines that derive logically from a desire to protect the environment, and these may be different from those used for other purposes, for example to maximise human comfort and material living standards.

In a previous book, the author introduced the idea of classifying issues by their ultimate consequence (24). A similar idea, end-product analysis, was advocated over a decade ago to encourage looking at the final results of a technology or set of beliefs, rather than being satisfied with the narrow objective study of sets of statistics and secondary local effects (25).

A classification by ultimate consequence will separate issues into groups based upon the type and severity of disbenefit that is or might be consequential upon ignoring the issue. Within each group, ranking can then be attempted. For example, the greenhouse effect and depletion of the earth's ozone layer are, on the balance of present scientific evidence, primary environmental issues. To ignore them may be to place in peril the balances of present-day Life-on-Earth. In contrast, there are many health and safety problems connected with buildings that although serious locally and on occasions, could never produce the same type of consequences.

Also, environmental issues cover a wide area and embrace many existing regulations and criteria. Trivial translation of a regulatory standard from one area (the work environment, for example) to another (weekend leisure pursuits) can quickly lead to nonsense.

Many areas are covered by existing regulations, others by the real fear of litigation should occupants become ill as a consequence of poor building design, construction or maintenance. Giving credit within an assessment for designing out water ponding in wet cooling towers to limit the risk of an outbreak of Legionnaires' disease may be a good idea, but no longer should it be claimed as an advance on normal good practice in a new building. It may however be used as an example of conscientious redesign of an existing system, but only until such refits become standard practice.

Most regulation within buildings (and other areas) is framed with the general idea of limiting risk. However, two examples may be used to illustrate that regulations may best be limited to specific areas of application, and that peoples' perceptions of risk, and reactions to it, depend very much on the source of the risk.

It is also essential to realise that not all risk can be avoided irrespective of expenditure and that the nature of the risk should be assessed with reference to consequences. Benefits often involve taking a risk and it is ridiculous to pretend otherwise.

Few people might argue that regulations covering the strength and testing of devices used for access to exterior faces of tall buildings for maintenance purposes could realistically be applied to solo rock climbing. Insurance companies recognise the different levels of risk involved.

Similarly there are stringent and detailed regulations for exposure to ionising radiation in the work-place, whether the radiation is from the natural environment or from a man-made source, such as a nuclear reactor (26). However, there are no regulations covering what potholers and cavers may do at weekends, and which may involve exposure to radiation doses vastly greater than would be tolerated in industry (27).

Peoples' perceptions of risk and the level of risk that they find tolerable are thus much influenced by circumstances, however illogical this may appear to be. Risks from radiation provide perhaps the best examples because calculated dangers cover a wide range from insignificant to horrendous, and with little corresponding spectrum of public understanding.

Many parents who would baulk at the idea of exposing their children to intense ultraviolet radiation from artificial lamps in an experiment to induce premature skin aging seem eager to suffer collective sunburn on holiday, with thousands of cases of cancer as a result. These risks can easily be minimised, unlike some from the natural environment.

Less popular than sunburn is voluntary exposure to ionising radiation, but there are thriving local enterprises in some parts of the world where patrons receive sizeable doses because of a belief in curative properties, for example for arthritis. Within mainstream science, there is an unresolved debate concerning whether small doses of ionising radiation are harmful, have no effect, or are beneficial (28) (29) (30).

Guidelines for regulatory protection from ionising radiation suggested by the International Commission on Radiological Protection distinguish between two circumstances of exposure. Human activities can either introduce new sources or modes of exposure and thus increase the calculated risk, or they can reduce exposure to existing sources, thus decreasing the risk. However, quite different dose limits may apply and it is recognised that to attempt to limit naturally occurring exposure using the criteria developed to prevent increased exposure could result in expenditure out of all proportion to the benefit obtained. It is not easy to rationalise this argument, yet it provides an illustration of how risks can be set into context or classified before deciding upon the response. (31)

(c) The example of drinking water in the USA

Levels of risk above regulatory concern as applied to man-made contamination of drinking water supplies, for example, cannot simply be applied to naturally occurring hazards, which are sometimes much greater. An example here is radon, and the conflicts that have arisen in the USA between different Divisions within EPA. For many years the Safe Drinking Water Act (SDWA) has been used to limit contaminants in drinking water to very low levels of calculated risk - typically one in a hundred thousand to one in a million, expressed as lifetime exposure risks for a fatal cancer.

The SDWA was framed with man-made pollution in mind and not the much higher calculated risks from background levels of radon in water. Treatment of all drinking water to remove radon to the 'one in a hundred thousand' calculated risk level is nonsensical on two counts.

Firstly, it would be more efficient in many cases to further reduce radon entering buildings from the ground (and not via the water supply) and secondly because even radon in fresh air gives a calculated lifetime risk of around 1 in 10,000, and which sets an upper limit on what might be attempted in risk reduction (32). This has not prevented promulgation of regulations for radon in water that even some EPA scientists will admit are absurd.

(d) A few conclusions

It needs to be accepted that different levels of concern may be appropriate in different situations and in different countries despite that levels of risk and avoidable risk might vary by orders of magnitude, and even when the source of the risk is identical. Lack of understanding of this point of logic has led to billions of dollars of 'environmental' expenditure to mitigate minute health issues, whether real or imagined. The environment has not benefited.

One of the first analyses that highlighted the importance of classification of issues to produce logical responses was published in the USA (33). It is argued that consideration of the relatively large risks that are accepted in return for the benefits of living in houses (such as a 0.5% or 1 in 200 chance of dying in a home accident) or the larger risks associated with driving cars, should lead to a more realistic perspective on environmental risks in general.

Also, it is implied that risks within each context, for example, transport, use of buildings, outdoor air, may need to be addressed at different levels of regulatory concern. Even different types of health risks may not necessarily be viewed on a common basis because some give rise to acute illness (such as allergic reactions and

sick building syndrome and which may not be tolerated) and some to more hypothetical risks, such as cancer many years in the future.

The article is also amongst the first to criticise the lack of marginal cost-effectiveness analysis as applied to regulatory concerns about indoor air pollutants. Two examples are cited, both from the USA, where it has been proposed to limit indoor formaldehyde concentrations to zero and to limit indoor radon levels to those outdoors.

Both proposals are criticised for failing to recognise that the risks that might be avoided are well within the range that are normally accepted within the context of living indoors. It is a quite separate argument to recognise that the risks avoided might actually be zero, because scientists cannot be sure of the effect of exposure to pollutants at very low levels.

However, if value for money and especially marginal cost-benefit were to be calculated, vastly more might be achieved by enhancement of mainstream health budgets. Alternatively, resources could be devoted to ameliorating primary environmental problems. A few illustrative calculations were recently published in the medical press (34), which continues to carry occasional articles exhorting better consideration of cost-benefit, for example (35).

(e) The absurdity of overregulation

In formulating the definition of primary health issues (see Section 2.4) it is helpful to recognise that whereas buildings can potentially kill people in many ways (gas explosions, structural collapse, falling from balconies or down stairs, inhalation of carcinogens, and in fires) such deaths are comparatively rare in the UK and often the fault primarily of occupants rather than of building design. Most UK buildings are already very safe places, owing to acceptance of good design standards and regulation, but there has been a tendency recently to take regulation to absurd extremes.

One of the most publicised and bitterly contested issues was the proposed introduction of new fire regulations that would have required massive expenditure without a firm scientific basis (36). There were similarities to what has happened in the USA within the EPA, and especially within two of its largest programmes, those dealing with asbestos and radon within buildings.

In the UK also, recent environmental health legislation, and especially its implementation by a few overzealous and inexperienced Environmental Health Officers has been the subject of a series of damming newspaper reports (37). The debacles exposed in these articles are notable primarily for the illustrations they provide of policy confusion and the often perverse effect of ill-thought-through legislation. Supporting letters have highlighted the need for a widely applicable methodology to help determine rational responses, and especially to separate out benefits to the environment from those to health and safety (38).

(f) Health effects in buildings

Consideration of the health of occupants in a building, in as much as it is influenced by the building or its operation, can be separated neatly into two areas:

Examples would be (i) a cooling tower that could produce Legionella or (ii) insulation material or carpets that were responsible for excessive emission of volatile organics into the indoor air. In these cases the culprit material (or supplier) could be identified.

There are, inevitably, people who don't like their work environment and feel that it makes them ill. SBS may be said to be present when the number of complaints is excessive, or suddenly increases, when no unique set of symptoms occurs and when no unique solution to alleviating them is available. Many of the symptoms are perhaps best classed as discomfort, in that no treatable illness can be diagnosed.

Design of buildings to ensure occupant health is thus a mixture of the easily comprehended and the mysterious. Many problems classed as sick building syndrome have their origins in poorly designed, badly commissioned or irregularly maintained heating, ventilating and air-conditioning (HVAC) equipment.

Contrary to some popular belief, SBS does not occur only in air conditioned buildings. Indeed, using some quantitative measures (degree of temperature control, humidity control, removal of particulates) the air in conditioned buildings is often of 'better' quality than that either in naturally ventilated buildings or outdoors in city centres.

However, not all sick buildings have basic HVAC parameters that are out of the ordinary and there are still many uncertainties as to cause and effect. Overseas, the health rating of buildings is often much less satisfactory, even within Europe, but improvements must not be lauded as dedication to environmental awareness. Making buildings safe for people to live and work in has little to do with their effect on the environment and is therefore a marginal issue for environmental assessment.

The present methodology provides a logical framework within which these disparate issues may be addressed.

(g) The resulting classification

The underlying logic of the above discussion is central to buildings' environmental assessment. Buildings are complex systems, and the built environment impacts on issues as diverse as global warming, thermal comfort, aesthetic perceptions, wildlife conservation, health risks, energy systems engineering, ozone depletion, materials use and recycling.

From within this complexity must be extracted a logical approach for encouraging better environmental performance (however defined) by enabling sensitive design of developments and appropriate building design and operation to be recognised.

With a few key definitions and ideas it is thus possible to deduce the objectives of environmental assessment, and from which follows the classification of issues.

The issues are:

1 Primary environmental

2 Secondary environmental

3 Primary health

4 Secondary health

Within an assessment framework based on this classification it is necessary to consider that design details that are especially damaging to the environment should not only be criticised but may be considered to render the scheme liable to outright disqualification.

Thus, a new housing development constructed to the latest energy efficiency, safety and security standards might appear ideal in both building and 'environmental' terms for occupants, but if it had been located on an important Site of Special Scientific Interest (SSSI), perhaps conveniently bulldozed prior to planning consent having been sought, the development (but not the building design) might be disqualified, on the grounds of having offended greatly against a primary environmental concern.

Similarly, the construction and operation of a new beach-side hotel or office complex that essentially destroyed the breeding sites of rare sea turtles should not qualify for any environmental acclaim, whatever the energy efficiency rating, however well landscaped the golf courses, and however perfectly the air filtration systems removed pollen for the greater comfort of guests or workers.

Such outcomes from assessments are entirely alien to the philosophy outlined in the original edition of BREEAM, where habitat destruction is accorded mention only as "an issue where suitable criteria for assessment have not yet been developed" (6). This is a curious assertion, since the science of ecology and rating of land utility for wildlife including SSSI designation in the UK predated BREEAM by many years. The explanation is simply that many important and contentious issues were effectively ignored in the rush to produce the first edition. Further information is given in Section 4.

Issues that are important for the environment can be ensured of appropriate attention in all countries only if:

(i) a logical set of definitions is adopted and

It needs to be recognised of course that achievement of a local benefit may in itself incur primary environmental disbenefits elsewhere sufficient to warrant disqualification. There will be no unique solutions, simply because so much of environmental science is both qualitative and concerned with trade-offs.

This difficulty touches on another underdeveloped area. There is no well-established assessment methodology for building materials. Indeed, further development of the whole methodology is recognised to be necessary before definitive assessments designed to rank building proposals one against the other can be produced. This is in progress and a key question is the degree of refinement that should be attempted once the core methodology is in place.

The principal aims of EIA can be satisfied by proper attention to defining the scope of the assessment and proper consideration of the key impacts. There will probably never be agreement on the relative importance of many secondary issues. Compilation of ever longer lists of 'good' and 'even better' building characteristics, especially if centred primarily upon local environment and health, could all too easily deflect attention from the primary issues. Indeed, this appears already to be happening.

The four issues of environmental assessment will now be discussed.

2.2 Primary environmental issues

The starting point for a methodology is to recognise that primary environmental issues centre upon irreversible damage to ecosystems over any sensible time-scale.

Examples of primary environmental issues are the destruction of tropical forests, marine ecosystems, coral reefs, and associated species that are adjudged to have no economic value. Far from being a concern over the extinction of just a few species, which has always been a part of the evolutionary process, the maintenance of biodiversity is now recognised as probably a major factor in maintaining fit conditions of air and water on the Earth (39). A more complete discussion of the rationale for maintaining diversity is available (19). Likewise, ozone depletion and global warming are primary environmental issues because of possible ultimate consequences.

Objective for primary environmental issues : to limit the amount of primary environmental damage caused by construction and use of buildings and development of land

It is clear that many aspects of building design may need to be judged against best practice to avoid or minimise primary environmental damage. Some aspects, for example thermal insulation standards, are already regulated in many countries but often with emphasis on allowing designers freedom to achieve an acceptable overall result rather than attempting to dictate each design parameter.

In other areas also, achievement has resulted from a dual approach - education and enforcement. However, as issues become discerned to be more urgent there may be an increasing emphasis on compulsion, if only to pre-empt the slow educational process. Restrictive global agreements, for example the 1987 Montreal protocol for limiting use of ozone depleting chemicals are less common than national or area Standards, for example limiting temperatures in buildings to save energy 'in the public good'.

However, these may be increasingly necessary if countries are to accept restrictions that would disadvantage industrial performance if applied selectively. An example here is the idea of a world carbon tax on use of fossil fuels to help limit global warming. Much of the outcry by industry against the idea of a European tax is rooted in the idea that the rest of the world might not follow suit. Of course, countries with a much higher than average proportion of nuclear or hydro generated electricity could benefit from any penalty imposed on use of fossil fuels.

The objective of limiting adverse impact on primary environmental issues would be achieved by measures including:

2.3 Secondary environmental issues

Secondary environmental issues often centre upon the local environment and may be argued to be all-important within the area or country concerned. Nevertheless, the test must remain that of ultimate consequence: would the legacy of world environment alter irreversibly if the issue was neglected? For many acutely-felt local issues the answer must be a resounding "no". Of course, local protest groups might not agree, but what they often protest about is not the wider environment but a piece of their own and dearly cherished backyard, and often in terms only of local traffic or noise levels.

Objective for secondary environmental issues : to limit the amount of secondary environmental damage caused by construction and use of buildings and development of land

Despite that local issues are usually of secondary importance some may be primary, even if they have very tight geographical boundaries. One example is the destruction of breeding sites for a rare animal. If the consequence is that the world would lose one of the last few habitats for a threatened species, the issue is of primary environmental importance. Any credible methodology for buildings' environmental assessment would exclude such a development from significant credit, rather than allow a good overall ranking to be produced because of attention to details such as storage facilities for waste paper. This would apply no matter how small the area of land involved.

Often however, local perspectives may be rooted more in self-interest than in wider concern. Creating another pond or planting a few trees may be entirely adequate to compensate for local development. No primary issue may be involved. Nevertheless the distinction between primary and secondary environmental issues may sometimes be blurred, and dependent upon scale.

It would be useful to draw up a list of particular primary concerns in each country where environmental assessment is undertaken, and for those from which building materials or products are imported. A necessary prerequisite would be zoning of land areas to define those that should remain untouched by intrusive development.

The concept of land exchange also needs further discussion. This may not of course extend to planting conifers to replace an area of ancient broad-leaf woodland, since the two could never be comparable in ecological value, but it would be tempting and probably worthwhile to consider schemes under which developers could be charged a high price for alteration of an area of environmentally sensitive land.

In exchange, they could be required to purchase and bequeath a larger area as a nature reserve, which in time and under management of a recognised and independent wildlife body could exceed in genuine environmental value the area destroyed. Whilst environmental considerations would be satisfied, local protesters would probably not be content. The issue then would be compensation for economic and amenity loss, but not net environmental damage in the wider sense. Provision for compensation to the environment might with advantage be built into environmental assessments of developments, and could have encouraged discussion in some recent well publicised arguments about a few trees being uprooted to make way for a new supermarket.

Similar logic may be applied to one of the most misrepresented of all environmental problems. Disposal of low level nuclear waste galvanises all manner of environmentalists, most or all of whom may know nothing of the real magnitude of the risks involved, yet who would argue passionately that the environment was at risk from an alien technology.

In reality, the environmental consequences of any sensible disposal of low level nuclear material are probably zero. Indeed, it has even been argued that sensitive nature reserves could benefit from an adjoining nuclear dump - at least people might be kept away from the flora and fauna.

The objective of limiting adverse impact on secondary environmental issues could be achieved by measures including:

• encouraging reuse of previously developed sites

• encouraging the reuse of building materials

• designing buildings to accommodate change of use

2.4 Primary and secondary health issues

In contrast to the consequences that attach to environmental issues, health issues are characterised by the only unwelcome effect being upon individuals or a population. Confusion is common when it is something in the local environment (or the indoor air) that gives rise to a real or imagined risk to health. The risk is one to health despite an environmental origin, and to be a primary issue there must be a significant chance of severe injury or premature death.

The term secondary health issues includes minor and reversible effects such as eye strain, sore throats, SBS, glare, poor lighting conditions, irritation from chemicals in indoor air and noise. Some of these might not even be classed as health issues, but considered (merely) as minor discomfort. Deliberately excluded are effects such as RSI (repetitive strain injury) which arise from processes undertaken within the building but which are not connected in any way with basic building design or operation.

Objective for health issues : to produce buildings that do not detract from the health and general well being of their occupants and those in the neighbourhood

The objective of limiting adverse impact on peoples' health could be achieved by measures including:

Exposure to indoor air pollutants has become a major issue and with increasing evidence of harm to health. However, some exposure to more ubiquitous pollutants such as radon and formaldehyde may not be avoided, and it may not be sensible to attempt avoidance (33). Whilst publicity often centres upon acute problems in large (and often new) office buildings, domestic wood burning stoves that are widely used in many American States have been implicated in respiratory problems.

The aim in addressing indoor air pollutants should be to achieve levels as low as is reasonable having regard to risk factors, economic factors and practicability. It should be remembered that building health risks are generally small if specific illnesses such as Legionnaires' disease can be avoided by systems design.

A difficulty in advocating high standards for indoor air quality is that consumption of energy and other raw materials and manufactured products such as air filters will inevitably increase. Thus, point scoring for including pollen filters in ventilation systems and unnecessarily low radon, formaldehyde and carbon dioxide levels may be counterproductive in overall environmental terms.

For many years it has been recognised that buildings' energy use can be reduced by allowing indoor parameters such as temperature and humidity to 'float' in sympathy with outdoor conditions. Similar trade-offs should be applied to indoor air quality, and with maintenance of the highest indoor standards being acknowledged to produce more external pollution. This is only recognising that a minimum use of building services and other engineering systems is generally better for the outdoor and wider environment.

Against this it may be argued that workers in 'very healthy' offices might work better, thus offsetting the extra costs of providing the cleaner environment. Similarly it has been argued for years (and widely practised) for office temperatures in the UK to exceed the statutory maximum of 19 C in wintertime. In either case, business benefits may accrue, or may be claimed to accrue, but the wider environment may be the loser.

2.5 Operational phase of the building or development

Environmental and health issues can be assessed at the design stage of a building. Indeed, assessment may be a useful part of the design process. However, the impact of a building or development may be as much determined by how it is operated as by design parameters, many of which may represent good intentions rather than achieved reality.

Objective for operational phase : to ensure that the building or building development maintains or improves its environmental performance year upon year

This is a challenging objective, both because of the scope of the demands that may be made on management and because of the lack of any definition of environmental performance. However, the importance of addressing operational issues is highlighted by the fact that for many decades in the UK, commissioning and maintenance of buildings and building service systems was neglected by developers, occupants and regulators.

Before the widespread adoption of air conditioned buildings in the 1960s in which occupants generally had less control over the indoor environment, it was usual practice to compensate for inadequacies in design and control by adjusting sunlight and ventilation rates to achieve tolerable conditions. Thus, opening windows was as much a part of control of heating systems as the room thermostat, if one existed or was still functioning.

Energy conservation initiatives concentrated attention onto control systems. It was soon realised that many buildings either had never been commissioned properly or control systems had fallen into disrepair and with no-one being responsible for their upkeep. Similarly, few buildings had any management control over energy use - fuel bills simply arrived and were paid.

The legacy of poor maintenance and repair persists in 1993 especially in the industrial buildings sector. The two key reasons why decades of neglect passed virtually without comment were that fuel prices were low in relation to wage costs (there has been little change here) and in the UK at least, qualifications for buildings maintenance staff were low.

Thus, staff who were adequate to maintain old coal fired boilers could not cope (and could not be expected to cope) with faults that developed in modern control systems. One of the main reasons why so much old heating plant was replaced in the 1970s and 1980s was not the fuel cost savings that could be achieved but that 24 hour cover was no longer essential. The savings were made by cutting staff.

More relevant for environmental assessment, the consequences of poor system commissioning and maintenance have included many HVAC related illnesses, including cases of Sick Building Syndrome where a cure has been effected by proper attention to room temperature, which can help to restore humidity and airborne concentrations of volatile organics to more normal levels.

In summary, commissioning and competent maintenance of buildings, and especially those used as work places, is now regarded as essential for continuing good energy performance and avoidance of buildings related illnesses and discomfort. However, there is a wide range of practice, and scope for better than average commitment to be recognised.

Environmental assessment must accept a moving target - with 'good marks' being given only for design or performance beyond current good practice. As with other Standards, yesterday's excellence can quickly become today's norm, and an assessment should remain current only if the building or development continues to be operated so as to achieve or surpass the goals set within the initial assessment.

Examples would be continuing achievement of energy conservation and limiting the release of ozone depleting chemicals from air conditioning plant. Once issues are properly quantified, operating a building to extremes of indoor air purity may be positively discouraged. Until then, common sense may be a good guide.

The prerequisites for good environmental management include a firm and continuing commitment by the Company or Companies occupying the building or by the appointed Managing Agents. Specific topics to be addressed on a continuing basis may be primarily those highlighted in the initial assessment at the design and construction phase.

Typically these will include:

2.6 Stages in assessment process

Environmental assessment of buildings and building developments is sometimes viewed as a single step during the design process. Ideally the process should commence with the site selection, coexist with the entire design and build phase and continue through into the operational phase.

It may sometimes be convenient to undertake EIA in three stages.

Stage one: site selection

Stage two: design and construction

Stage three: operation of the building or development.

However, an overall assessment may need to take into account that some environmental damage at the construction stage may be ameliorated by long term commitment to genuine environmental improvements to the site. Factors such as this need further refinement within the methodology, and illustrate the danger of undertaking a single snapshot assessment.

Within each Stage, the scope of the assessment should be determined to concentrate attention on the issues most relevant for the particular building or development, and public consultation needs to be maintained.

2.7 Discussion of market forces

To achieve the objectives of environmental assessment on a large scale may require more than the current voluntary approach. However, much could be achieved indirectly by market forces acting in response to central initiatives such as:

• increasing fuel prices in real terms on an annual basis

In addition, a more insidious influence operates in oversupplied commercial property markets. Buildings must match the needs of prospective tenants. Perhaps never again will tenants be willing to accept whatever floor-space they can get at whatever price. Buildings that are adaptable to different needs - even conversion from offices to housing in inner city areas - may have a significant market advantage. This strikes at the heart of fabric and services design and wise developers should take note.

The challenge for building designers is to ensure that change of use can be accommodated without detriment either to energy consumption or health and comfort of occupants. Elements of the external building fabric may need to be adaptable, especially in respect of fraction of glazing to optimise solar input as a function of changes in internal heat generation. In environmental terms the important parameters are:

Ensuring flexibility becomes more important as plant complexity and size increases, and is of most concern therefore in highly serviced buildings. Flexibility of the building fabric may be especially important if large changes in internal heat loading are anticipated, and even to the extent of altering wall U-values as well as glazing fractions and characteristics.

In addition, many building designs allow for changes in internal layout. The HVAC systems must be able to accommodate these, and complex buildings especially should have a comprehensive design and commissioning manual to assist new owners or tenants achieve low energy consumption. Buildings that cannot be offered with the assurance of full operational details may be disadvantaged.

2.8 Workbook or environmental log

Whenever possible environmental assessments should be published. These should include the key factors identified for the particular building or development as being of importance for annual review. This would place buildings' assessments in advance of audits to BS 7750, which do not have to be published, but on a par with Company Eco-audits, which are required to be published.

Thus, the initial assessment could comprise

2.9 Conclusions

The core of a logical methodology has been developed, based not upon cause or locale but on effect, and especially upon ultimate consequence.

Definitions and examples have been given of primary and secondary environmental issues. Similarly, health issues in buildings have been logically addressed. When more completely developed the methodology will be applicable to all buildings and building developments worldwide.

It has been highlighted that a clear distinction needs to be drawn in respect of whether design details are required (by regulation or fear of litigation) or are included out of a desire to make the building or development in some way better than the norm.

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