Comments on BREEAM - February 1991
Background notes added February 2006:
During the early development phase of BREEAM, several senior BRE scientists had serious reservations about the increasingly 'commercial' nature of the Establishment's work and the requirement to produce output that best fitted what 'the market' (or government ministers) wanted to hear, as opposed to the 'blue skies' research for which BRE had become renowned over decades. Some saw 'the writing on the wall' and just kept quiet. Others left or took early retirement. Within the space of a few years BRE lost almost a generation of highly competent and knowledgeable scientists.
It was all at a time when creeping privatisation and 'cost recovery' was all the rage within government. Conversion of BRE to an Executive Agency was seen as a first step to full privatisation. BREEAM was seen as a potential money spinner, and from the start it was promoted within glossy covers as a major contribution to the Department's environmental programme. In earlier times it would have merited the status of an Internal Note - these documents being for discussion within the Establishment and not deemed worthy of extensive external promotion - at least until the basic science had been reviewed. But in the early 1990s the ethos was more on marketing than on academic integrity. BRE management were (understandably) keen to use BRE's reputation to ensure a dominant position for as many 'commercially viable' initiatives as possible. This was to be aided by their ability to let research or development contracts using government money to outside contractors who could be relied upon to 'tow the line'.
The note reproduced below survived my enforced departure from BRE (more details here) and together with other material from the time, can be used to plot the true history of BREEAM. It may not be exactly the same as the minute I sent to Dr Prior all of 15 years ago but it is certainly almost identical.
BREEAM was initially, and seems to have remained, primarily a marketing and publicity exercise. Like all bandwagons, it was easier (and often profitable) for consultants or hard pressed university departments to jump on than to get in the way. Nowadays, jobs are even advertised for full time 'BREEAM assessors' and this would (no doubt) be argued to be further evidence of the scheme's universal appeal.
Some of the central comments included in what follows now seem prescient. Publicity in early 2006 surrounding James Lovelock's latest book 'The Revenge of Gaia' shows just how far removed from reality are many government schemes for addressing environmental problems - and how little ministers are prepared to address the looming issues of population and consumption excess. A review of the book will be published on SeeRed in due course.
Dr J Prior.
Environmental Physics Division
Building Research Establishment.
BREEAM.
I promised to send you a brief comment on BREEAM following your talk on 23 January. We have since discussed the matter briefly, and may I confirm my appreciation that I was allowed to attend. I recognise this caused some unease, but cross-border communication is recognised as a key ingredient of successful companies.
My principal point is that the words Environmental & Environment are much misused. BREEAM merely continues what is fast becoming a shameful and almost ubiquitous practice: jumping on the environmental bandwagon.
"Environmental Concern" in the recent "green" sense within which BREEAM seeks its essential appeal and credibility is concerned primarily and even (some would say) exclusively with developments (changes) that are already affecting or that may soon affect the capacity for part or whole of Life on Earth to survive. These changes can legitimately be seen as the only ones that really matter.
The essential ingredient that distinguishes a true environmental issue is irreversibility over any sensible time-scale of damage to diverse ecosystems. Principal examples are the destruction of tropical forests (proceeding at a wholly unsustainable rate and with the likelihood of total destruction of many unique regions within a decade or so) and destruction of marine ecosystems and coral reefs, and all their associated specialised species that are adjudged to have no economic value. The phrase "Extinction is forever" has been coined by environmentalists.
The upsurge in popular concern for "The Environment" is quite distinct from that centred upon health issues, where the primary and perhaps only unwelcome effect is necessarily transitory and upon people. There is some evidence that this distinction is recognised, but it is not yet well articulated even in the major environmental groups. 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.
Similarly, it is a moot point whether minor and reversible effects such as eye strain or sore throats should really be classed as health issues. Already therefore you could envisage a classification of issues based not on cause or locale but on effect: the judgement should be on ultimate consequence, but having regard to cost-benefit analysis to help ensure that resources are not deployed inappropriately. Some of the confusion surrounding domestic radon has its origins in the desire by zealots to treat it as a nuclear issue, since upwards of £100,000 per dwelling and many international conferences might then be devoted to remediation. In its proper context as an assumed and minor health matter, expenditure would be calculated against a background of other health costs and benefits, and only the highest level UK houses would be seen to merit concern in the near term. Incidentally, you will find it easier to progress BREEAM towards 'economic' weighting of different issues if your initial classification is logical.
I would therefore suggest the following classification:
true environmental issues (as outlined above)
health issues (substantial illness such as Legionnaires' disease, cancer or leprosy, and including ill-health brought about by environmental factors: smog and open sewers, for example).
minor inconveniences (ingrown toenails, eyestrain, PRM)
I have included sewers because although BREEAM 1/90 is clearly meant for the UK, the principles could find wider application: all the more reason for logical analysis.
Within even future UK versions of BREEAM, I would advocate that you should separate out more clearly the possible benefits from better attention to building design:
Environmental benefits,
Health benefits,
Comfort benefits.
I have already mentioned to you that the present scheme is all positive. Whatever you do you get one or more credits or (at worst) none. Any scheme looked at as a whole needs an assessment of environmental disbenefits too.
Achievement of a benefit in any of my three categories may in itself incur environmental disbenefits: the use of energy to provide an unnecessarily high standard of space conditioning is an obvious example. "What a super environment in this building". You already have the beginning of a scheme that could attempt however imperfectly, to list benefits and environmental costs for any proposed design feature or system. For some issues, a quantitative balance could be given. You are probably too young to remember all the debate in the 1970s on the energy cost of energy saving measures, and on the concept of energy quality. The concept of the solar breeder embraced consideration of both quality and quantity on both sides of the equation. Due regard for cost-effectiveness helped ensure that raw materials were not squandered in manufacturing millions of environmentally friendly solar collectors, for example. A Select Committee (as I recall) recommended grants for householders to install the things, and probably the same purulent standard of analysis will soon be applied to 100,000 radon systems.
Returning for a moment to definitions (never a bad place to start!), you may know that I have been sensitised to misuse of terminology within the radon field. Logically, the only effect of radon is to shorten the lives of a small number of people. (It is unnecessary within the present discussion to consider whether or to what extent radon in houses poses a real threat.) Calculations of cost-benefit belong within the health arena, but it is for building scientists to become involved if incompetence is demonstrated by those whose remit should include rational assessment of the importance of a health-in-buildings issue.
One example will suffice: the first order effect on and the benefit to the Environment from dealing with radon in buildings is zero. Yet radon has been referred to as the biggest environmental problem faced by the United States. Despite a frantic and alarmist publicity campaign led by career zealots in the EPA, public concern about radon has remained low. It may be conjectured that people have an innate sense that something entirely natural and that has been present since the world began cannot suddenly constitute an environmental hazard. In this they are correct, and soon the voices of scientists as opposed to those of the opportunist zealots may be heard.
Consider the real environmental problems that are central to the excessive consumption and population within North America, Europe and Japan (for example): loss of species, expansion of deserts, disruption of the atmosphere, loss of forests, despoliation of the seas: none of these are directly influenced by whether radon is addressed. Indeed, average outdoor concentrations of radon would be very slightly increased by operation of millions of systems to keep radon out of buildings. The effect might be to increase slightly the cancer rates of wild animals! Despite that radon kills people, it does not even manage to address the curse of over-population, since its effects occur well past breeding age. Second order arguments can be advanced in either direction: if radon kills a key Environmentalist before he has time to finish his Life's work, that is a disbenefit in environmental terms. However, radon reduces use of raw material by shortening the lives of predominantly rich people: those who live in houses. This is a benefit in environmental terms. However much you may disagree with the arguments, the logic is sound.
It is hypocritical of BREEAM 1/90 to say that its main objectives include avoidance of false claims of environmental friendliness. If I was a free-range environmental consultant, I would already have mauled this first version, unless of course I was being paid to improve it.
The principles upon which revision should be based are clear. Discussion of issues (and award of credits and discredits) should proceed under distinct but logical headings. Thus, Legionnaires' disease would need mentioning only once (as a health issue) and some degree of ranking of health issues could readily be achieved. It is not logical to separate out Legionnaires' disease into both Neighbourhood and Indoor Effects (even supposing these were logical categories for anything) because many of the deaths from an infected cooling tower might occur amongst the occupants of or visitors to the building. (Remember Stafford Hospital?). Likewise, asbestos is a (very minor) health issue. It does not make much sense to classify it as an Indoor Effect, since in some circumstances the concern is to the Neighbourhood: upon demolition of the building or in a fire for example. Indoor levels are often very low until the material is disturbed.
I would be pleased to offer assistance with the detailed work that is required, provided that my contribution were to be acknowledged in the usual way. Indeed, I would like to think I had contributed enough already to be mentioned as a contributor to BREEAM 2!
I would offer one other brief comment resulting directly from your talk on 23 January. During the discussion period Dr Raw advanced the argument that BREEAM must be thought very worthwhile and valid because, to date, over 50 major buildings had been submitted for assessment. This is not, as I have explained to you, an endorsement of BREEAM. It is (merely) a reflection of the fact that a few developers have calculated £3000 to be a small price to pay for what they perceive may be perceived by others to be in some sense, a BRE Approval of their building. I doubt many of them are taken in by the inherent inadequacy of the present version, even if they've studied it. I have no doubt either that requests for buildings to be BREEAMED will continue, at least until such time as there is some organised public comment. I well remember discussing with Dr Leach in a BREEAM meeting that the key reason why developers were bothering to cooperate with BRE was that they saw the value of being associated with BRE's reputation.
I would offer two small suggestions to extend consideration of wildlife habitat (mentioned in Reuse of an Existing Site). Five discredits would be awarded for each and every notable wildlife site destroyed by the construction, and 20 discredits for destruction of an SSSI. If you consider these matters to be trivial, what is asbestos mentioned for?!
A credit would be given if the designers could show that they had incorporated significant features within the building or its immediate environment that encouraged wildlife, in particular rare species. Examples would be sensibly designed lakes and large areas of hedges and other cover. It is of course possible in this field as in others to do much to little effect. BRE could seek advice from one or more of the key wildlife charities (WWFN, RSPB, etc) who have the necessary expertise. Indeed, it could be a requirement that companies wishing to have their buildings BREEAMED would have to pay a consortium of these charities for a wildlife assessment. At least it would force some developers to make their first contact with an ecologist. If you wish for a volunteer, I would be content to talk to some of the wildlife charities about the extent to which they considered any involvement potentially useful. I note that BREEAM includes a commitment to consult extensively with environmentalists.
Since discussing this with you I have seen the BREEAM Press Release of 13 February 1991. I will refrain for now from commenting at length on the content, but one claim is in the same league of absurdity as the Audi "green" advertisement. In this, all the carbon dioxide from a clean and green car is explained to be (merely) the gas that makes fizzy drinks fizzy: the implication being that all the rich owners of new Company-owned Audis can breed to excess and drive thousands of miles per year to their crèches, playgroups and recycling centres secure in the knowledge that their impact on the environment is no more than that of a few fizzy drinks.
Consider now the claim that "to achieve credits on the green label of a BREEAM certificate a building MUST BE MUCH LESS ENVIRONMENTALLY DAMAGING TO ......THOSE WHO WILL OCCUPY THE BUILDING THAN ONE BUILT TO NORMAL PRACTICE."
I am leaving a detailed analysis of this pernicious perversion until I next have a couple of minutes to spare. I am also leaving discussion of parts of your recent article in Structural Survey. Whilst Editors will be pleased to learn that BREEAMED buildings must not cause environmental damage (sic) to their occupants, they may discover (if they bother to read beyond the glossy cover) that insufficient information is available to address SBS. Thus, it is entirely possible that a fully certificated building will turn out to be as sick as the proverbial parrot. Also, it appears that there is insufficient evidence that airborne organisms can have a serious environmental (health) effect: presumably this excludes Legionella.
I am copying this minute to a few colleagues on the BRE IAQ Liaison Group and to a few others who were concerned with the development of BREEAM, and with the request that you should collate responses, if any.
Stephen J Wozniak
Head of Building Pathology Section
Building Research Establishment
16 February 1991