BRE aims to double its turnover as a business from £40m to £80m.

It aims to do this before 2016 when, if the government has its way, there will not only be a full-blown Code for Sustainable Homes, but a Code for Sustainable Everything: offices, hospitals, schools… you name a category, and the BRE will probably have been commissioned to codify the design parameters.

Meanwhile, designers struggle on with the Code for Sustainable Homes, built on the shifting sands of changing rules determined by BRE, a private company. It’s impossible for developers to work out which way the code will go. How can they plan or research?

The problem is that there isn’t an independent body like the British Research Establishment used to be pre-privatisation – which can carry out the development of codes and regulations. The introduction of competition from private firms, combined with a lack of support, has eroded the knowledge base within local authority Building Control. There isn’t a Ministry of Construction packed with experts and advisers who could do this work.

The Codes for Sustainable This and That will create a market for fee-charging code assessors, themselves charged a fee by BRE for accreditation. No longer can a developer go to Building Control for approval. They will need to get the nod and pay for it from a tranche of independent assessors.

One of the biggest uncertainties for designers relates to the Standard Assessment Procedure (SAP) for calculating energy performance of buildings. Created in 2001, SAP needed great improvement in 2005 and is still supposed to be ‘tweaked’ by the end of 2007.

SAP is supposed to allow buildings to be compared for their energy performance. It is central to the Code for Sustainable Homes, which requires a percentage improvement on SAP2005 to get a code level rating, Code 5 being 100% better.

But there is a problem with SAP2005. Designers know already that the 14 SAP calculation software tools they are directed to use by the BRE give different answers to the same input data.

These difficulties have to be resolved if designers are to work with the Code for Sustainable Homes. Designers of the Kingspan house, which achieved Code level 6 and was unveiled at Offsite 2007, had to employ a ‘modified’ SAP method, with BRE’s permission, in order to attain level 6. But it isn’t available to others yet.

And BRE is not intending to fully correct SAP for real world subtleties such as thermal mass of buildings until 2010, even though they have known SAP was deficient since 2001. Why can’t SAP be corrected now? There are too many moving goalposts.

Who will sort SAP out? It was the job of a company called FAERO. Set up to accredit a competent persons scheme for the issuing of Energy Performance Certificates, FAERO hoped for a monopoly. However the government would not license it as the sole accreditation authority. Consequently, unable to see where the business would be secure, FAERO ceased trading in August 2007.

Which leaves BRE. But it has other things to do, including finishing its Green Guide 2007 materials ratings that the Code for Sustainable Homes and no doubt the forthcoming codes depends in part upon.

Finally, there’s the mystery of how the scoring system for the Code for Sustainable Homes works. BRE has inserted weightings into these. Obviously these could change, but nobody can predict how.

In effect this means that BRE could follow its own agenda under license from the government. If politics are to be played with designers, then the government should take direct responsibility. An £80m business should not be built in partnership with government on the back of SAP chaos and code tinkering.