The Planning Officers Society has only general comments to make to the BRE.
We wonder whether the technical manual meets its own requirement to be "a reference for clients and members of the project team whose proposed building is being BREEAM assessed" as we contend that it is unlikely to be used easily by a planning officer.
On a wider point we are concerned as to how BREEAM will fit into the new ways of working envisaged in last year's consultation: Housing Standards Review. This reflected industry criticism of the different codes which LPAs apply and saw eventually all of these being subsumed into the Building Regulations. We await the Governments follow up to that consultation. There was a suggestion in the consultation that Government may seek an interim stage which would allow LPAs to use standards they had in policies in their adopted local plans which related to "nationally prescribed standards". We are aware that these standards are not specifically mentioned in the consultation but could include BREEAM.