Energy, Sustainability and Carbon

BREEAM credits usually fixed before planning submission

7 min readBy PlanScope Editorial Team

A pre-assessment is an estimate, not a certificate. The transport, ecology, surface water and daylight credits are largely settled before the application is submitted.

Most of the BREEAM credits you will ever win on a scheme are decided before the planning application is submitted, by the site you bought, the form you drew and the consultants you appointed. A BREEAM pre-assessment at planning stage is an estimate of where the design is heading, not a certificate, and the honest value of doing it properly is that it tells you whether the rating your local plan policy demands is actually reachable before a condition fixes it.

What a pre-assessment is and what it is not

A pre-assessment is a scoring exercise against the relevant BREEAM scheme, usually BREEAM UK New Construction or the refurbishment and fit-out scheme, carried out by a licensed assessor using the published estimator. It identifies credits as targeted, possible or not achievable, and produces an indicative score against the rating bands.

Those bands are fixed: Pass at 30 per cent, Good at 45, Very Good at 55, Excellent at 70 and Outstanding at 85, each with mandatory minimum standards that have to be met whatever the headline score. A scheme can score 72 per cent and still fail Excellent because it missed a minimum standard in the energy or water category. Pre-assessments that report only the percentage are doing half the job.

It is not certification. Certification happens at two later points, a design stage assessment producing an interim certificate and a post-construction assessment producing the final one. Nothing in a pre-assessment is auditable, and no certificate exists until the design stage submission is reviewed.

A BREEAM pre-assessment is one of the report types councils usually expect to be authored by a licensed assessor, so treat an AI-assisted draft as the structure and the policy framing, with the scoring signed off by someone who holds the licence.

Credits fixed by the site and the layout

Several credits are settled the day you exchange on the land, and no amount of later design effort recovers them.

Transport credits turn on how accessible the site is by public transport and on the facilities within walking distance. An out of town plot scores badly and keeps scoring badly. Land use and ecology credits reward previously developed land and penalise building on land of higher ecological value, so a greenfield site starts behind. Surface water credits depend on whether the site is in a flood zone and on whether run-off can be attenuated to the required rate and volume, which is a function of ground conditions and levels.

Daylight and visual comfort credits are set by massing, floor to ceiling heights, glazing ratios and the depth of the plan. Once the planning drawings fix the envelope, the daylight credits are fixed with it.

Credit area Decided by Last point to influence it
Transport and accessibility Site selection Before purchase
Land use and ecology Site selection and survey timing Before site clearance
Surface water run-off Site levels and drainage strategy Concept design
Daylight and visual comfort Massing, plan depth, glazing Planning submission
Energy and carbon Form factor, fabric, services strategy Concept to developed design
Materials and waste Procurement route and contractor Technical design

Credits that depend on an early appointment

The management category is where developers lose credits through programme rather than through design. Several issues require evidence that a named role was appointed, or that a particular exercise was carried out, by a specified RIBA work stage.

The clearest example is the requirement for a BREEAM Accredited Professional to be appointed by concept design and to be involved through the project. Appoint them at technical design and the credit is gone, permanently, because the evidence cannot be backdated. The same applies to stakeholder consultation on the project brief, to a pre-demolition audit before anything is knocked down, and to ecological survey work carried out in the right season by a suitably qualified ecologist.

So the practical move is to read the credits that carry an appointment or timing trigger, list them, and put the appointments in the programme before planning submission rather than after.

Note that credit reference codes differ between scheme versions, and schemes are reissued periodically. Check which version your assessor is registering the project under, because a policy written against an older version can create an argument at discharge of conditions.

When a targeted rating becomes a planning condition

Many adopted local plans require a stated BREEAM rating for non-residential development above a floorspace threshold, and the authority secures it by condition. Typical wording requires the rating to be achieved, a design stage certificate to be submitted before works begin or before a defined trigger, and a post-construction certificate within a set period after occupation.

Read that wording carefully before you agree to it. Three problems recur.

  1. A condition requiring an absolute rating with no fallback leaves you in breach if a credit is lost for a reason outside your control, such as a change in the certification scheme.
  2. A condition requiring the design stage certificate before works begin can delay a start on site by months, because certification is not instant.
  3. A condition that names a rating without naming the scheme version invites a dispute about which version applies.

Negotiating a condition that requires the development to be designed and constructed to achieve the stated rating, with the design stage certificate submitted before occupation of the relevant phase, is usually achievable and much less risky than the standard template.

The gap between pre-assessment and design stage

A pre-assessment is optimistic by nature, because at that point everything is still possible. Design stage assessment is where the optimism meets evidence requirements, and the drop is usually between three and eight percentage points if the pre-assessment was honest and much more if it was not.

The common causes are specification changes made for cost, services decisions taken late, and energy credits that assumed a better fabric performance than the thermal detailing delivers. Our note on thermal bridging detail at planning stage covers the last of those, and the same discipline applies to the Energy Statement that sits alongside the BREEAM work.

Build a buffer. If the condition demands Excellent at 70 per cent, target 74 or 75 in the pre-assessment and identify which credits you are holding in reserve. Name them in the submission so the officer can see the scheme is not balanced on a knife edge.

Evidence the authority asks for at discharge

Discharge submissions fail on paperwork more often than on performance. What the case officer needs is the certificate issued by the certification body, in the name of the development as described in the permission, at or above the rating in the condition.

Where the condition also asks for a submission before works begin, provide the registered pre-assessment or design stage report with the assessor's licence details, the scheme and version, the score sheet by category and a short statement mapping each mandatory minimum standard to the evidence. Where a credit has been dropped since planning, explain the swap rather than hoping nobody checks.

As an illustrative example, an office refurbishment targeting Excellent might sit at 71 per cent in the pre-assessment with two innovation credits assumed. If one of those falls away during tender, the scheme drops below the band and the condition is breached. The same scheme pre-assessed at 75 per cent with the innovation credits excluded would have absorbed it.

Avoiding a condition you cannot meet

The underlying judgement is simple enough to state and hard to hold to. Do not offer a rating in the planning submission that the design cannot carry, because the offer becomes the condition and the condition binds the build contract.

Where the local plan sets the rating, test it against the real constraints of the site before you submit. If the site cannot reach it, say so in the Sustainability Statement, explain which credits are unavailable and why, and propose what the scheme can achieve instead along with the carbon and energy measures that go beyond policy elsewhere. A reasoned case for Very Good with a strong Whole Life Carbon Assessment and a fabric first energy strategy is a better planning position than an undeliverable Excellent.

This is general guidance rather than legal advice, and for specialist technical reports, qualified professional input may be required. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.

Frequently asked questions

Is a BREEAM pre-assessment the same as certification?

No. A pre-assessment is an indicative score produced with the published estimator and is not auditable. Certification happens later, through a design stage assessment that produces an interim certificate and a post-construction assessment that produces the final one. A planning condition usually asks for one or both of those certificates.

What are the BREEAM rating thresholds?

Pass at 30 per cent, Good at 45, Very Good at 55, Excellent at 70 and Outstanding at 85. Each band also carries mandatory minimum standards, so a scheme can exceed the percentage and still miss the rating by failing a minimum standard in a category such as energy or water.

Which credits are lost by appointing people late?

The management credits that require a named role or exercise by a specified work stage. Appointing a BREEAM Accredited Professional after concept design loses that credit permanently, because the evidence cannot be backdated. Pre-demolition audits and seasonal ecological surveys carry the same kind of timing trigger.

How should a BREEAM planning condition be worded?

Ask for the development to be designed and constructed to achieve the stated rating, with the design stage certificate submitted before occupation of the relevant phase and the scheme version identified. Avoid an absolute rating with no fallback and avoid a requirement for certification before works begin, which can delay a start on site.

Who can prepare the pre-assessment?

Councils usually expect a licensed assessor, and the scoring needs someone who holds that licence. An AI-assisted draft can set out the structure, the policy framing and the credits engaged by the site, but the score sheet and the registration with the certification body have to come from the assessor.

Sources and further reading

breeamsustainabilityplanning conditionsdevelopersenergy

This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.

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