Michael Gove, James Review, NPPF and BREEAM





After this week’s news that Michael Gove is considering removing the requirement for new schools to achieve BREEAM ‘Very Good’ I have had a look at the James Review again and I believe that this shows that the report steers towards deregulation very clearly. I have included a link below to the report and put a couple of excerpts from this.

James Review

3.18 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. … 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

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.

4.13 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.

I believe that moving away from BREEAM would send a very poor message to the construction industry, particularly contractors, as new schools should be of the highest sustainable design possible. Although BREEAM is not perfect there is no other standard presently used in the UK that can match it. By moving away from this there is too little legislation or incentive to build to a low carbon and sustainable standard.

If a different standard is to be proposed the Government needs to define this but BREEAM should be retained until this happens. In addition to this local planning departments are revising local plans that generally appear to require BREEAM assessments (Hampshire and Portsmouth will from 2012; requiring ‘very good’ to ‘excellent’ in 2013) for large scale non domestic applications, therefore this would will add to the confusion.

I have looked at the National Planning Policy Framework and this is very vague, it states the phrase “presumption in favour of sustainable development” (mentioned 19 times) but does not define what this is. It tries to illustrate some examples of “unsustainable” (mentioned once) development but preferably a clear definition of what this is should be included and I believe that a credible standard would illustrate this, such as BREEAM.

Sustainability can mean very different things and the NPPF draft appears to be pointing towards more housing and economic sustainabililty, not low carbon, low energy and low impact development. Michael Gove appears to be moving in a disappointing direction regarding sustainability and it remains to be seen if this comes about, I believe that BREEAM should be retained and any move away from this should be to a credible and higher standard such as Passivhaus standard in time.


Foreword Development that is sustainable should go ahead, without delay – a presumption in favour of sustainable development that is the basis for every plan, and every decision. This framework sets out clearly what could make a proposed plan or development unsustainable.

p.31 The presumption in favour of sustainable development means that Local Plans should be prepared on the basis that objectively assessed development needs should be met, unless the adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole. Applications should be considered in accordance with the presumption. Planning permission should be granted where relevant policies are out of date, for example where a local authority cannot demonstrate an up-to-date five-year supply of deliverable housing sites.


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