The BRE alternative to the Code for Sustainable Homes

The Building Research Establishment has seen the Government steer its campaign against red tape in the direction of the Code for Sustainable Homes and is resigned to the sustainability of housing to be the responsibility of the Building Regulations. The BRE has also seen the signs in the 2014 Queen's Speech that the Zero Carbon Homes by 2016 commitment is to be qualified (no more than the equivalent of CSH5 will be required) and that small sites (yet to bhe defined) will be exempt. These changes has caused confusion about whether planners would be able (ie in law) or willing, to remain engaged in the control over the sustainabilty of buildings (including housing), particularly as the NPPF/Framework contains the 'presumption in favour of sustainable development'; the golden thread that still runs through plan-making and decision-taking. It seems to me that development plans should logically repeat the Bruntland definition of sustainable development from the Framework, and adopt the analogy of an appeal inspector of the need 'to consume its own smoke'. The 'presumption' implies that planners should also stay involved in decision-making - considering whether any development benefits from the 'presumption' and, if not, (eg significantly lower than zero carbon for even a small number of houses), refuse permission. A BRE 'kite mark' for sustainable development could be very useful, and the following is my response to its consultation. Found at http://www.bre.co.uk/page.jsp?id=847 (respond by 25 July 2014)
My thoughts on the use of a 'kite mark' follow the above reasoning, that the 'presumption' and 'golden thread' in the Framework oblige planners to remain engaged in assessing sustainability - not just energy efficiency. At the very least developers should be obliged to build show houses to the highest standard and offer this to potential purchasers. The BRE have set out a number of criteria and, in response to three of them,
* mental and physical health & wellbeing of occupants
* resource efficiency
* low energy, water and maintenance costs, I have suggested the following.
Taking the above criteria into account jointly or severally, the highest accreditation should be applied (reserved) for co-housing that implies and, through the design, should be able to demonstrate a level of sharing of land and buildings that represents a highly efficient use of resources in construction and subsequent use. The 'intentional community' would share the caring for children, the disabled, the sick and elderly, and enhance mental and physical health. Co-housing would also facilitate the sharing of spaces for work and play that increase the wellbeing of the residents. Preserving this highest accreditation for co-housing would be a signal to developers and planning authorities (including parish councils/neighbourhood forums) that the models of housing provided in at least the last 60 years have not been amenable to sharing and have instead encouraged the unsustainable resource costs associated with private and exclusive use. In the case of the design of individual dwellings (outside of co-housing developments with commonhouse and other shared spaces where individuals and families can meet their needs for indoor and outdoor space), there should be 'points' awarded or deducted for the ease with which a dwelling could be reconfigured to smaller (or indeed larger) units. Circulation (eg external doors and stairs), services (plumbing and electrics), gardens and parking should be designed so that subdivision could be carried out at reasonable expense. This would enable smaller households to downsize without moving and would address unsustainable levels of under-occupation, particularly prevalent in rural and suburban areas.