Archive for January, 2011

Ireland’s Proposed Climate Change Legislation – Shambolic !!

2011-01-30:  ANYWAY … continuing on from yesterday …

In December (2010) … Mr. John Gormley T.D., Irish Minister for the Environment, Heritage & Local Government published the 2010 Climate Change Response Bill.  This proposed legislation is intended to set out a range of measures to statutorily underpin Ireland’s transition to a sustainable, climate change resilient and low carbon-based fuel consuming society … not forgetting, always (!), that there are other Greenhouse Gases (GHG’s) specified in the UNFCCC’s 1997 Kyoto Protocol besides Carbon Dioxide (CO2) … which most people do forget.

The Minister had then invited interested parties to submit their views on the Bill – available to download from the Department of the Environment, Heritage & Local Government (DEHLG) WebSite at  … by Friday, 28 January 2011.  Three other documents which were relevant to this ‘consultation’ are:  an Explanatory and Financial Memorandum on the proposed legislation, the Bill’s Regulatory Impact Assessment and the Minister’s 2011 Carbon Budget Dáil Statement.

In his 2011 Carbon Budget Speech to the Dáil (Irish Parliament), the Minister had proclaimed the following …

” In providing a legislative underpinning for proactive transition, it (the 2010 Bill) presents the Irish people as an informed and progressive society pursuing a smart economy in the truest sense of the term – an economy that is highly productive, competitive, resource-efficient and environmentally sustainable.”   and

The Bill is both innovative and inspirational, and I look forward to a frank and honest public debate when it is published.”

WOW !!!   Hold De Horses !!!!


Two important national lobby groups have recently thrown some spanners into the works … the Irish Farmers’ Association (IFA) raised some positive and interesting issues which should be brought to the attention of DG CLIMA in the European Commission … see this Page on the IFA WebSite … … while the Irish Business & Employers Confederation (IBEC) have been predictably negative and a right pain in the ass … see this Page on their WebSite …

The well-publicized positions adopted by these lobby groups prove the point, however, that far more than slick marketing campaigns are required to raise popular awareness about climate change … to properly mobilize society for climate change action, i.e. adaptation as well as mitigation … and reliable implementation.



As far as Irish Senior Civil Servants are concerned … the temporary, blow-in politicians (also referred to, by them, as ‘defecating birds of passage’) … in this particular case, Mr. John Gormley … have merely departed the scene … this time, a little earlier than expected.  But, the permanent system of national dysfunctional governance, i.e. the Civil Service, continues to ride on into the golden sunset … serving their own interests, and not always the country’s !

Whatever is happening at a political level … you should still have regarded Friday, 28 January 2011 … as the latest date for receipt of written responses on Ireland’s Proposed Climate Change Response Bill.   If slightly late, get those responses in anyway … as early as possible after the weekend !

The Civil Servants in the Department of the Environment, Heritage & Local Government (DEHLG) need all the help that they can get !!



On 14 December 2010, the Economic & Social Research Institute (ESRI) published a report: ‘The Energy & Environment Review 2010’ … available for download at … which contained a certain Figure 6.  Please bear in mind that there are large uncertainties associated with all of the data contained in the document (see more below) … a point acknowledged by the ESRI …

Colour image showing Figure 6: 'Greenhouse Gas Emissions by Gas According to the Low Growth Scenario' ... from the Economic and Social Research Institute (ESRI) Report: 'The Energy & Environment Review 2010', published in December. Click to enlarge.

Colour image showing Figure 6: 'Greenhouse Gas Emissions by Gas According to the Low Growth Scenario' ... from the Economic and Social Research Institute (ESRI) Report: 'The Energy & Environment Review 2010', published in December. Click to enlarge.


Ireland’s Climate Change Action to date, i.e. effective Climate Change Mitigation and Adaptation Implementation, has been laboriously slow and lethargic.  It may best be characterized as ‘Business as Usual’, combined with some ‘Cosmetic Tinkering at the Edges’ as the need arises … the universal excuse, almost a mantra, being that “the competitiveness of the national economy must not be impaired”.  National Performance has been guided by an official policy of exploiting to the maximum all of the UNFCCC Kyoto Protocol’s Flexibility Mechanisms while, at the same time, showing a stark indifference to Climate Change Adaptation … an over-reliance on Marketing Campaigns in the public media as opposed to mandatory implementation on the ground … and a preference for ‘Soft’ Performance Estimation on paper/computer monitor screen rather than the more painful ‘real’ performance calculation, which would generate reliable data and statistics to be managed by Ireland’s Central Statistics Office (CSO), in co-ordination with EuroStat in Luxembourg.

Figure 6 from the 2010 ESRI Report … indicates that Official Ireland only ever had a short-term strategy, which was to meet the Kyoto Protocol’s 2012 GHG Emission Reductions Target … on paper !   Right now, it looks like we may only just manage to meet that Target because of the current serious economic recession.  This performance improvement … temporary only … masks fundamental problems within Irish Society.  After 2012, all bets are off … as we won’t be in a position to meet any reasonably foreseeable EU or International GHG Emission Reduction Targets.  If economic growth takes off again, in Ireland, during the second half of this decade … not a completely mad notion … we will be in real trouble !

The Department of Environment, Heritage & Local Government (DEHLG) lacks strong and competent political direction and the institutional capacity to effectively co-ordinate, oversee and implement National Climate Change Action.  For this reason, closer scrutiny of the Department’s activities, from the Dáil Committee System, will be an absolute necessity.

Ireland’s proposed climate change enabling legislation … the 2010 Climate Change Response Bill … is the belated manifestation of a shambolic and pathetically inept effort on the part of Mr. John Gormley, T.D. … and the Senior Civil Servants in the Department of the Environment, Heritage & Local Government (DEHLG) !

Why, So, Because … ?



     1.  In the light of elaborate claims made about this proposed legislation and also, for example, the separate project to establish an International ‘Green IFSC’ in Dublin … the 2010 Climate Change Response Bill will be closely examined outside Ireland … particularly by the most advanced ‘developing’ economies and the ‘least developed’ economies of the world.

However, a keen awareness about the highly divisive and difficult political issues at the heart of current international climate change negotiations would have dictated that the following be discussed in a Preamble or Introductory Section to the Bill:

  • An acknowledgement of Ireland’s Historical Responsibility for contributing to global climate change ;
  • A national commitment to fully support the move towards an Internationally Agreed Cap of 1.5 degrees Celsius on the planetary temperature rise ;
  • A national commitment that Ireland will meet its International & European Union Climate Change Obligations through the efforts of Irish Society alone.  In other words, we will not seek to benefit, unfairly, from any of our Foreign Development Aid to countries in Africa and Asia … or to projects in Africa, Asia, the Western Balkans, Eastern Europe, Palestine or the Caribbean.

[All such Foreign Development Aid from Ireland should be immediately ‘climate change’ proofed.]

     2.  It is only economists who mistakenly believe that everything in society is merely an ‘input’ to economic ‘output’.  Mercifully, the rest of us know otherwise.  A Society is much, much more than its Economy !

It is a fundamental value and principle that All Aspects of Sustainable Human & Social Development must be taken into account at the same time and with the same weight.  A blinkered approach which only considers the environmental aspects of this overarching concept is damaging, and seriously counter-productive in the longer-term.

The case study of the Proposed Shannon River – Dublin City Region Water Supply Project … discussed in a previous post … very clearly shows that there is a symbiotic Relationship between the Concept of Sustainable Human & Social Development and the Reality of Climate Change … a robust link which is critical to the development of an elusive Global Consensual Response to the threat … and essential for the effective implementation of any Climate Change Strategy in Ireland.

The Existing Lines 11-15 in the 2010 Bill are conceptually flawed … and drafted carelessly and imprecisely.  Revise these lines accordingly …


For Consistency … Revise Section 5 (3) (a) – Section 5 (6) (a) – Section 6 (1) (a) – Section 9 (1) – the final portion of Section 10 (2) – and Section 11 (1) (c) of the Bill.

     3.  No satisfactory explanation has ever been given, in Ireland, for not choosing a Common Baseline Year of 1990 for all of the Kyoto Greenhouse Gases.  Revise Section 2 (2) of the Bill as follows …

For the purposes of this Act –

(a)  the baseline year applicable to a class A greenhouse gas shall be 1990;  and

(b)  the baseline year applicable to a class B greenhouse gas shall be 1990.

In Section 4 (1) – Section 4 (2) – and Section 4 (3) of the Bill … Revise all GHG Emission Reduction Targets and express them, clearly and simply,  in terms of the single Common Baseline Year of 1990.

Thankfully … Ireland’s GHG Emission Reduction Targets will be dictated to us as a result of Agreements at International and/or European Union levels.  Any aspirations with regard to Ireland taking a lead role in climate change action, at any level, are pure fantasy !

     4.  National GHG Emissions – Towards Reliable Data and Statistics

At present … the National ‘GHG Emission’ Database is managed by the Environmental Protection Agency (EPA).  The EPA is not a statistical organization, and necessary statements of uncertainty are not presented with emissions data.  The National ‘GHG Emission’ Database is unreliable.

A major part of the EPA’s National ‘GHG Emission’ Database is dependent upon National Energy Consumption and Efficiency Performance Data.  The National ‘Energy’ Database is managed by Energy Ireland (SEAI).  Energy Ireland is also not a statistical organization, and necessary statements of uncertainty are not presented with energy data.  The National ‘Energy’ Database is unreliable.

For a number of years, however, Energy Ireland has been in possession of reliable information which shows that there is a dramatic difference between the claimed ‘theoretical’ energy conservation and efficiency performance of buildings at design stage … and the actual energy performance of ‘real’ buildings … such is the poor quality of construction on Irish Building Sites.  It is therefore possible to state, with confidence, that the National ‘Energy’ Database managed by SEAI is corrupt !

[See previous posts … Energy Ireland has consistently refused to release the full details of this information into the public domain.  I know, because I am tired asking !]

To be reliable … National ‘GHG Emission’ and ‘Energy’ Databases must be managed directly by the Irish Central Statistics Office (CSO), in co-ordination with EuroStat in Luxembourg … and necessary statements of uncertainty must always be presented with data.

A revised Climate Change Response Bill must confront this serious issue now … and deal with it properly.




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Petrol/Gasoline Prices in Turkey Now – Here Tomorrow ?

2011-01-30:  A Sobering Interlude …

Colour photograph showing the prices of different grades of petrol and diesel at a Petrol Station in Turgutreis, on the Bodrum Peninsula, Turkey. Photograph taken by CJ Walsh. 2011-01-21. Click to enlarge.

Colour photograph showing the prices of different grades of petrol and diesel at a Petrol Station in Turgutreis, on the Bodrum Peninsula, Turkey. Photograph taken by CJ Walsh. 2011-01-21. Click to enlarge.


The photograph above shows the prices for petrol (gasoline) on 21 January 2011 … in Turkey:

For 95 Octane Petrol (gasoline), the price shown is  3.98 TL  per Litre

The exchange rate at the time (2011-01-21) … € 1 / 2.04 TL  =  € 1.95  per Litre


For 97 Octane Petrol (gasoline), the price shown is  4.01 TL  per Litre

The exchange rate at the time (2011-01-21) … € 1 / 2.04 TL  =  € 1.97  per Litre




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Climate Change ?#$#? … 2007 SDI Letter to John Gormley !

2011-01-29:  Some people say that a week is a long time in politics … but, here in Ireland, during the last two weeks … every single day feels like a year !   To the uninformed outside observer, this may have all the appearance of being an elaborate circus … but, we like our politics to be complex, interesting and very frothy.

Briefly … the Irish Green Party has recently removed itself, awkwardly, from the Ruling Coalition Government in this country … and the Green Party Agenda has gone up in smoke … definitely a Climate Changing Greenhouse Gas !   Mr. John Gormley T.D., Leader of the Green Party, has therefore resigned as Minister for the Environment, Heritage & Local Government … and his Green Party departmental colleague, Mr. Ciarán Cuffe T.D., Minister of State with special responsibility for Sustainable Transport, Horticulture, Planning and Heritage at the Departments of the Environment, Transport and Agriculture has also resigned.

With all of Ireland’s current economic woes … this decision by the Green Party has ensured that ‘Climate Change’ is fast dropping off the list of national priorities.

However, as a result of these political shenanigans … the word ‘Green’ has received a severe hammering and will induce a nasty taste in the mouths of many Irish Voters during the next few weeks which lead up to a General Election.  To be honest, I heartily cheer this development … since ‘GREEN’-ness, i.e. a sole and blinkered consideration for the Environmental Aspects of Sustainability is a ‘pre-version’ (fans of the film: ‘Dr. Strangelove’ will understand what I mean) of Sustainable Human & Social Development.  It is also a peculiar quirk of ‘greens’ that they love the environment … but hate people !

As a prelude to what I will say about the proposed enabling legislation for climate change action in Ireland … the 2010 Climate Change Response Bill … I thought that it would be interesting to reveal the contents of a submission I made to Mr. John Gormley back in late 2007.  Concerning his reaction … I wondered how it was possible for anybody to write such a long letter in reply, and say nothing.


Mr. John Gormley T.D.,                                                                                           2007-12-18.

Minister for the Environment, Heritage & Local Government,

Department of the Environment, Heritage & Local Government (DEHLG),

Custom House – Dublin 1.

Re:  Your Meeting with IIEA on Friday, 7th December 2007

Dear Minister,

At the Meeting with the Institute of International & European Affairs (IIEA), in North Great George’s Street, I raised two points directly with you:

     i)   The Great Difference between ‘Real’ Building Energy Performance and Claimed ‘Theoretical’ Performance.   In a context where the mandatory use of long wave infra-red thermal imagery will not be introduced in the Revised Technical Guidance Document L of the Building Regulations, due to be issued shortly, and there will continue to be No Effective System of Building Control anywhere in the country … no relationship exists between Claimed ‘Theoretical’ Performance and ‘Real’ Performance, such is the poor quality of construction on Irish Building Sites.  The Energy Numbers which continue to be produced by Sustainable Energy Ireland are – almost – pure fantasy.

     ii)  Sourcing of Climate Change Research & Models for Necessary Institutional Reform Must Extend Beyond Britain.   The following is taken from the Irish National Climate Change Strategy 2007-2012 (page 45) …

‘ Ireland has also engaged in an exchange of information on impacts and adaptation activities through the British-Irish Council. This initiative has focused on exchanging data on research projects which have improved the understanding of climate change impacts at a local level.’

I suggested to you that if this were, actually, to be the approach to Research in Ireland … we will be in serious trouble.  Furthermore, far too many people in important organizations (including the IIEA) are only looking across the water for Models of Necessary Institutional Reform.  We must also, in Ireland, look to the rest of Europe and Japan to find the Best Research and the Most Effective Institutional Models.

Please see the enclosed World Business Council for Sustainable Development (WBCSD) Summary Report: ‘Energy Efficiency in Buildings – Business Realities & Opportunities’ (October 2007), which was presented at an important Paris Conference at the beginning of November, 2007.

This Report looks at what can be achieved in Europe and many other parts of the world – today – using currently available building technologies and systems … IF ‘real’ implementation is taken seriously.  Barriers to progress and costs have also been examined.

In the final analysis, however, a properly resourced Indigenous Research Capability, focused on Irish Conditions and Needs, is vitally necessary to drive ‘Real’ Performance and Innovation in this country.


Post-Bali Leadership from Ireland (and DEHLG !)

A Kyoto II Instrument will be agreed and ratified before the end of 2012.  The 1997 UNFCCC Kyoto Protocol must now be seen, therefore, as just the beginning of a long-term process which will last until the end of the century.  Some Necessary Direction and a large pinch of Ethical Leadership are urgently required to properly re-position Ireland in this Process.

The following Post-Bali Target Scenario for Ireland is presented for your consideration:

  • Ireland should set 1990 as the Benchmark/Base Year for All Kyoto Greenhouse Gases ;
  • Statements of Measurement and Calculation Uncertainty should be fully transparent (nationally, and at EU level), and made at every stage of Ireland’s Kyoto Compliance ;
  • The EU’s Objective of a 30% Reduction in Greenhouse Gases by 2020, compared to 1990, is the Relevant Short Term Target (refer to Paragraph 31 of the German Presidency Conclusions from the E.U. Council’s Brussels Summit on 8th and 9th March 2007) ;
  • As our ‘Real’ Performance, under Kyoto I, continues to be so weak and disingenuous … we should not expect to receive as generous an intra-EU burden sharing arrangement as before.  Instead, Ireland should adopt the 2020 National Target of a similar 30% Reduction in Greenhouse Gases, compared to 1990 ;
  • Our Contingency Target for 2020 should be a 33% Reduction in Greenhouse Gases, compared to 1990.  When considering ‘real’ performance in any field of human endeavour, it is usual to include a safety factor in any calculations …. in this case, 3% ;
  • Ireland’s Recourse to the Use of Carbon Sinks and Kyoto Mechanisms in meeting the 2020 Contingency Target should be restricted to 1/4 of ‘Real’ Performance …
    • ‘Real’ Performance (no sinks/mechanisms) – minimum 24% Reduction in Greenhouse Gases by 2020, compared to 1990 ;
    • Use of Carbon Sinks and Kyoto Mechanisms – 9% Reduction in Greenhouse Gases by 2020, compared to 1990 (this figure includes the contingency 3%) ;   and
    • As the Construction Sector (when properly identified) should share more of the national burden than, for example, Agriculture …. its Target should be a 40% Reduction in Greenhouse Gases by 2020, compared to 1990.  Remember the range of reductions which were initially proposed at Bali …. 25-40% ?
  • Part 1 of SDI’s Submission for the Irish Construction Sector (IIEA Climate Change Project, Sectors Sub-Group – June 2007) stressed the great need to properly restore the Construction Sector’s Infrastructure.  Otherwise, this Sector will not be able, in reality, to reach any Energy Performance Targets … low or high.  Of course, what will eventually appear on paper, or as a computer print-out, is an entirely different matter !

However, having been able to access information about the recent WBCSD Research Project, and using it as a valid substantiation … it then became possible to deal with the issue of Energy Performance Targets for All Buildings (new, existing and those of historical, architectural and cultural importance) more aggressively.

Enclosed, please also find Part 2 of SDI’s Submission for the Construction Sector (IIEA Climate Change Project, Sectors Sub-Group – November 2007).


Ireland’s Climate Change Strategy ?

     1.  Ireland’s Current ‘Real’ Situation with Regard to Kyoto (I) Compliance should be clearly understood by the Irish Public.  Using the recently issued European Environment Agency (EEA) Report 5/2007: ‘Greenhouse Gas Emission Trends & Projections in Europe 2007 – Tracking Progress Towards Kyoto Targets’, we have extracted just a few snippets of interesting information (enclosed) …

  • Instead of 1990, Ireland has chosen 1995 as the Base Year for HFC’s, PFC’s & SF6 ;
  • Ireland’s Per Capita greenhouse gas emissions are nearly the worst in the EU-27 ;
  • Ireland’s Per GDP greenhouse gas emissions are far too high ;
  • Ireland’s ‘Real’ Distance-To-Target (no sinks/mechanisms) is very bad.

Ireland is still grimly grasping on to a ‘Business as Usual’ Approach.  This is actually being reinforced by the relevant Institutions of the State, who insist on merely Playing with Numbers … and then publishing Cosmetic Public Relations Brochures for consumption in Ireland and, unfortunately, on the wider European and International Stages.

     2.  The following National Policy/Strategy Documents & Legislation should directly relate to one other, and their implementation should be tightly co-ordinated …

  • National Sustainable Development Strategy ;
  • National Climate Change Strategy ;
  • National Climate Change Adaptation Strategy ;
  • National Spatial Strategy ;
  • National Development Plan ;
  • National Public Procurement Law.

Not only have some of the above not yet even been drafted, but others are unacceptably inadequate, outdated and/or fundamentally flawed.  And the synergies which would normally accrue from co-ordinated implementation are being lost.

     3.  The World Business Council for Sustainable Development has identified Buildings as one of the five main users of energy where ‘megatrends’ are needed to transform global energy efficiency in the immediate short term, and so meet the daunting challenge of Climate Change Adaptation.  They account for 40% of primary energy (primary energy includes the energy required to generate, transmit and distribute electricity, as well as energy directly consumed on site) in most developed countries, and consumption is rising.

Nothing less than a Complete Cultural Shift will be necessary throughout this Sector, beginning with all research and design disciplines and extending right across to any person who works on a construction site or has any part to play in managing, maintaining or servicing a building.

Yet, Irish Construction is not presented as a Coherent Sector anywhere in National or European Greenhouse Gas Databases.

Separate Strategies are urgently required to greatly improve the energy performance of:

  • Existing Buildings … onto which many energy efficiency measures can be successfully grafted, but they will not be cheap ;
  • Buildings of Historical, Architectural or Cultural Importance … the integrity of which must be protected ;   and
  • New Buildings, which must therefore carry the major burden.

     4.  Raising the (General) Awareness of Irish Society regarding Climate Change and Mobilizing People and Organizations for (Effective) Action are two entirely different concepts.  Which concept is informing Strategy Development within the DEHLG ?

A €15 m. Marketing Campaign, spread over 4-5 Years and including the ‘Change’ WebSite (!?!?), will not mobilize anyone … to do anything.

     5.  Your proposals concerning Necessary Building Energy Efficiency Improvements to be included in the Revised Technical Guidance Document L are inadequate.  Part L should be applicable to ALL New Buildings.

It has also been insufficiently emphasized in public discussions/consultations concerning this issue that any proposed Building Energy Efficiency Improvements must take place in a context of stringent control during construction (by a sufficient number of competent Local Authority Building Controllers and/or Independent Technical Controllers) and rigorous post-construction energy performance monitoring (using long wave infra-red thermal imagery, in conjunction with building external fabric air seepage tests).  Follow-up observation of post-occupation building energy performance will also be required.

This is the one – and only – means of …

  • tweaking Computer Software Tools so as to produce more realistic outputs ;   and
  • obtaining reliable construction-related energy performance data and statistics.

Please Note Well:  Without suitable references to the use of long wave infra-red thermal imagery (essential, if working at ambient temperatures – short wave, if working at high temperatures) in Section 5, the Revised TGD L will be absolutely meaningless !!

Because of wasteful patterns of building management and/or use – even in the most energy efficient building – we would also stress that far more attention should be paid to the concept of Intelligent Energy Efficiency Management.

     6.  We strongly urge you, in accordance with the 2007 Bali Action Plan, to rapidly advance development of the National Climate Change Adaptation Strategy, and to ensure that it is properly implemented.

     7.  We call for the creation of an adequately resourced Sustainable Development Commission with the necessary legal mandate, independence and technical expertise to monitor – in an integrated, continual and proactive manner – Ireland’s mitigation and adaptation performance in relation to the adverse effects of climate change.  We also call for a New Social Partnership for Sustainable Development & Climate Change Adaptation.  Addressing Climate Change must be considered an integral element of Sustainable Development Policies.


At Sustainable Design International … we continue to find, in everyday practice, that the most challenging barriers to Policy Implementation are Institutional – lack of proper horizontal policy integration in Public Authorities, and antiquated approaches to management in Private Organizations.  At every level, the concept of Sustainable Human & Social Development is poorly understood.

Should you have any questions or comments, please contact me at your convenience.

Yours sincerely,

C.J. Walsh,  etc., etc.




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EU Accessibility & Ratification of UN Disability Rights Convention

2011-01-15:  Recently, I was waiting … and waiting … for the first mention of this important news to pop up on any of the European Disability Networks … the Formal Ratification by the European Union (EU) of the 2006 United Nations Convention on the Rights of Persons with Disabilities … on 23 December 2010 last.

History in the making !!

This U.N. Convention was adopted on 13 December 2006 (2006-12-13), at the United Nations Headquarters in New York … and was opened for signature on 30 March 2007.  It entered into force, i.e. became an International Legal Instrument, on 3 May 2008 (2008-05-03).  A copy of the Convention can be downloaded, here, on this Site … in my post, dated 31 October 2009.

Finally, on Monday 10 January 2011 … via ICTA-Europe, EDeAN, and the EU Press Release below … it was announced …

EU Press Release IP/11/4 – Brussels, 5 January 2011

EU Ratifies UN Convention on Disability Rights

Click the Link Above to read and/or download PDF File (25kb)

So much for instant communication in our much-vaunted Information / Knowledge / Smart Society !!


Ordinarily, this news would be nothing to get excited about.

BUT … since the Lisbon Treaty entered into force on 1 January 2009 … the European Union now has a legal personality all of its own, separate from those of the individual EU Member States.  See Article 47 in Title VI – Final Provisions – of the Treaty on European Union (consolidated version).

This is the first time that the EU has become a party to an international treaty.

The 2006 United Nations Convention on the Rights of Persons with Disabilities is now part of the European Union’s Acquis Communautaire, i.e. the extensive body of EU Law.


The consequential impacts flowing, therefore, from the EU’s Ratification of the U.N. Convention … at both European and Member State (National) levels … will be very, very interesting to observe during the immediate short term.  [A note of caution … be patient, and allow for a short period of ‘bedding-in’ at the start.  See below.]

The European Commission, for example, must now take full account of the Convention in the drafting and implementation of any new legislation, policies and programmes … in fact, all of its activities.

The European Court of Justice must also take full account of the Convention in all of its work.

This will, inevitably, heavily influence what is … or is not … happening with regard to social and other policies at national level in the Member States.  Many Member States (16) have already ratified the Convention … and more power to them !   BUT among these 16 … the Czech Republic and Denmark have not yet ratified the UN Convention’s Optional Protocol … how strange … and unacceptable !!

Some Member States … and I am thinking specifically of Ireland … will have to be dragged, screaming, to the point of ratification.  And even when that position has been reached … proper implementation will always be an issue.  Just consider, for a moment, Ireland’s uncaring and ham-fisted approach to implementation of the 1989 U.N. Convention on the Rights of the Child … which it did actually ratify way back on 28 September 1992 !   See my post, dated 30 November 2009.


Accessibility of the ‘Human Environment’ – A Harmonized EU Understanding !

As far as the European Union must now be concerned … and all of the EU Member States … Preamble Paragraph (g) and Articles 9, 10 & 11 of the 2006 United Nations Convention on the Rights of Persons with Disabilities – together – form the basis of a harmonized understanding for Accessibility of the ‘Human Environment’ … which includes the Built Environment, the Social Environment, the Economic Environment, and the Virtual Environment … concepts which I have defined, here, many times before.

Preamble Paragraph (g)

Emphasizing the importance of mainstreaming disability issues as an integral part of relevant strategies of sustainable development,

Article 9 – Accessibility

1.  To enable persons with disabilities to live independently and participate fully in all aspects of life, States Parties shall take appropriate measures to ensure to persons with disabilities access, on an equal basis with others, to the physical environment, to transportation, to information and communications, including information and communications technologies and systems, and to other facilities and services open or provided to the public, both in urban and in rural areas.  These measures, which shall include the identification and elimination of obstacles and barriers to accessibility, shall apply to, inter alia:

     (a)  Buildings, roads, transportation and other indoor and outdoor facilities, including schools, housing, medical facilities and workplaces ;

     (b)  Information, communications and other services, including electronic services and emergency services.

2.  States Parties shall also take appropriate measures:

     (a)  To develop, promulgate and monitor the implementation of minimum standards and guidelines for the accessibility of facilities and services open or provided to the public ;

     (b)  To ensure that private entities that offer facilities and services which are open or provided to the public take into account all aspects of accessibility for persons with disabilities ;

     (c)  To provide training for stakeholders on accessibility issues facing persons with disabilities ;

     (d)  To provide in buildings and other facilities open to the public signage in Braille and in easy to read and understand forms ;

     (e)  To provide forms of live assistance and intermediaries, including guides, readers and professional sign language interpreters, to facilitate accessibility to buildings and other facilities open to the public ;

     (f)  To promote other appropriate forms of assistance and support to persons with disabilities to ensure their access to information ;

     (g)  To promote access for persons with disabilities to new information and communications technologies and systems, including the Internet ;

     (h)  To promote the design, development, production and distribution of accessible information and communications technologies and systems at an early stage, so that these technologies and systems become accessible at minimum cost.

Article 10 – Right to Life

States Parties reaffirm that every human being has the inherent right to life and shall take all necessary measures to ensure its effective enjoyment by persons with disabilities on an equal basis with others.

Article 11 – Situations of Risk & Humanitarian Emergencies

[My Note: An outbreak of fire in a building would be a situation of serious risk.]

States Parties shall take, in accordance with their obligations under international law, including international humanitarian law and international human rights law, all necessary measures to ensure the protection and safety of persons with disabilities in situations of risk, including situations of armed conflict, humanitarian emergencies and the occurrence of natural disasters.


Accessibility of the ‘Human Environment’ – Competent & Effective EU Implementation !

Within the European Union as a whole, because it is a party to the Convention in its own right … and also within the individual EU Member States … Articles 31 & 33 of the 2006 United Nations Convention on the Rights of Persons with Disabilities – together – mandate that implementation is taken seriously … that it is competent and effective … and, most importantly, that independent monitoring and verification is a fundamental part of the process.

Article 31 – Statistics & Data Collection

1.  States Parties undertake to collect appropriate information, including statistical and research data, to enable them to formulate and implement policies to give effect to the present Convention.  The process of collecting and maintaining this information shall:

     (a)  Comply with legally established safeguards, including legislation on data protection, to ensure confidentiality and respect for the privacy of persons with disabilities ;

     (b)  Comply with internationally accepted norms to protect human rights and fundamental freedoms and ethical principles in the collection and use of statistics.

2.  The information collected in accordance with this article shall be disaggregated, as appropriate, and used to help assess the implementation of States Parties’ obligations under the present Convention and to identify and address the barriers faced by persons with disabilities in exercising their rights.

3.  States Parties shall assume responsibility for the dissemination of these statistics and ensure their accessibility to persons with disabilities and others.

Article 32 – International Co-Operation

1.  States Parties recognize the importance of international co-operation and its promotion, in support of national efforts for the realization of the purpose and objectives of the present Convention, and will undertake appropriate and effective measures in this regard, between and among States and, as appropriate, in partnership with relevant international and regional organizations and civil society, in particular organizations of persons with disabilities.  Such measures could include, inter alia:

     (a)  Ensuring that international co-operation, including international development programmes, is inclusive of and accessible to persons with disabilities ;

     (b)  Facilitating and supporting capacity-building, including through the exchange and sharing of information, experiences, training programmes and best practices ;

     (c)  Facilitating co-operation in research and access to scientific and technical knowledge ;

     (d)  Providing, as appropriate, technical and economic assistance, including by facilitating access to and sharing of accessible and assistive technologies, and through the transfer of technologies.

2.  The provisions of this article are without prejudice to the obligations of each State Party to fulfil its obligations under the present Convention.

Article 33 – National Implementation & Monitoring

1.  States Parties, in accordance with their system of organization, shall designate one or more focal points within government for matters relating to the implementation of the present Convention, and shall give due consideration to the establishment or designation of a co-ordination mechanism within government to facilitate related action in different sectors and at different levels.

2.  States Parties shall, in accordance with their legal and administrative systems, maintain, strengthen, designate or establish within the State Party, a framework, including one or more independent mechanisms, as appropriate, to promote, protect and monitor implementation of the present Convention.  When designating or establishing such a mechanism, States Parties shall take into account the principles relating to the status and functioning of national institutions for protection and promotion of human rights.

3.  Civil society, in particular persons with disabilities and their representative organizations, shall be involved and participate fully in the monitoring process.


The European Union’s Disability Strategy 2010-2020 [COM(2010) 636 final]

The general approach to, and the quality of, Accessibility Implementation in Europe … when compared, for example, with Japan … is pathetically inadequate.

It is quite amazing, therefore, that the texts which deal with Accessibility of the ‘Human Environment’ in the EU’s Disability Strategy Document 2010-2020 … are weak and far too vague … basically, meaningless claptrap drafted by desk jockeys / ‘suits who do not know’ !   We did not achieve a ‘Europe Accessible For All’ by 2010 (see below) … do you see it ??   And … at the current rate of progress, neither will we achieve a ‘Europe Accessible For All’ by 2020 !

The European Union’s Accessibility Strategy, related Policies and Programmes … and the monitoring, targeting and independent verification of Accessibility Implementation … all require a radical overhaul !

All those Officials in the European Commission who are involved, in any way, shape or form, with Accessibility of the ‘Human Environment’ would do well to RE-READ AND MEDITATE DEEPLY on the contents of the 2003 Final Report from the Group of Accessibility Experts, which was established by the European Commission itself …

EU 2003 (EYPD) Expert Group on Accessibility

October 2003

2010: A Europe Accessible For All

Click the Link Above to read and/or download PDF File (294kb)

I was a Member of that Expert Group !



1.  The European Union HAS NOT RATIFIED the UN Disability Rights Convention’s Optional Protocol.  If the Union is so Open and Transparent … and so committed to Human and Social Rights for All EU Citizens … somebody, somewhere, has to scream out loud “Why is the EU Not Ratifying this Optional Protocol ???”.   And … we demand an honest answer !!!

Optional Protocol – Article 1

1.  A State Party to the present Protocol (‘State Party’) recognizes the competence of the Committee on the Rights of Persons with Disabilities (‘the Committee’) to receive and consider communications from or on behalf of individuals or groups of individuals subject to its jurisdiction who claim to be victims of a violation by that State Party of the provisions of the Convention.

2.  No communication shall be received by the Committee if it concerns a State Party to the Convention that is not a party to the present Protocol.

2.  The EU Code of Conduct between the Council, the Member States and the Commission setting out internal arrangements for the implementation by and representation of the European Union relating to the United Nations Convention on the Rights of Persons with Disabilities.  Above, I talked about a short period of ‘bedding-in’.   BUT … get your teeth into the ‘meat’ of this document … which indicates that it might be a much longer and more difficult process !?!

Official Journal of the European Union (15 December 2010) – 2010/C 340/08

EU Council – UN Disability Rights Convention – 2010 Internal Code of Conduct

Click the Link Above to read and/or download PDF File (729kb)

3.  At EU Council … How Important is this Issue Considered ?   In the 37 Page Report on the Justice and Home Affairs Council Meeting, which was held in Brussels from 2-3 December 2010 … the adoption of the above Internal Code of Conduct rated just a very brief mention on the last page.  It was not mentioned, at all, among the Main Results of the Meeting !

4.  Will Disability Networks, at both European and Member State (National) levels, have the stamina … and be sufficiently competent and focused … to rigorously monitor European Union Implementation of the UN Disability Rights Convention ??   And … will these Networks be courageous in challenging the EU Institutions … if Implementation is found to be Inadequate ???   I’m not so sure !




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Carbon Monoxide (CO) Protection in Building Habitable Spaces

2011-01-13:  Carbon Monoxide (CO) is an odourless, colourless and toxic gas.  Because it is impossible to see, taste or smell the toxic fumes, CO can kill you before you are aware it is in your home.  At lower levels of exposure, CO causes mild harmful effects which are often mistaken for the flu (influenza).  These symptoms include headaches, dizziness, disorientation, nausea and fatigue.  The effects of CO Exposure can vary greatly from person to person depending on age, overall health and the concentration and length of exposure.  Source: Environmental Protection Agency (EPA), USA.

Recent tragic deaths from CO Poisoning have occurred in Ireland … not only in the home, but also in a hotel.

Sources of Carbon Monoxide (CO) … unvented kerosene and gas space heaters; leaking chimneys and furnaces; back-drafting from furnaces, gas water heaters, wood stoves, and fireplaces; gas stoves; generators and other gasoline powered equipment; automobile exhaust from attached garages; and tobacco smoke.  Incomplete oxidation during combustion in gas ranges and unvented gas or kerosene heaters may cause high concentrations of CO in indoor air.  Worn or poorly adjusted and maintained combustion devices (e.g., boilers, furnaces) can be significant sources, or if the flue is improperly sized, blocked, disconnected, or is leaking.  Car, truck, or bus exhaust from attached garages, nearby roads, or parking areas can also be a source.  Source: EPA, USA.


If there is a fuel burning / heat-producing appliance in any habitable space, in any building … and if you have not done so already … you must do something NOW to check that you are protected effectively from CO Poisoning.  Shift your ass !

In order to improve energy conservation and efficiency in buildings … direct, natural ventilation from the exterior is still being actively discouraged … and buildings are becoming more tightly sealed, during construction or major refurbishment, to prevent unintended air seepage.  Generally, this has been causing a serious increase in Building Related Ill-Health (also known as ‘Sick Building Syndrome’) … much of which is still going un-reported.



1.  Check that there is sufficient, clear, direct natural ventilation in any habitable space which contains a fuel burning / heat-producing appliance.  Next … Check that the terminal unit / outlet of the flue coming from that appliance is not blocked.  Then … Check the route of any flue from the appliance.  If, for example, a flue passes through another habitable space … that space must also be properly ventilated.

2.  Check that all fuel burning / heat-producing appliances are ‘fit for their intended use’ (this must be shown !), are working properly … and that they are regularly serviced by people who are competent to do so.  Paperwork is not a reliable indicator of competence !   Remember the problems with FÁS !?!

3.  Do not confuse Carbon Monoxide Detectors with Smoke Detectors !   Only install a dedicated Carbon Monoxide (CO) Detector for the task of detecting Carbon Monoxide.  And … that Detector must be shown to be ‘fit for its intended use’.  Read the writing on the outside of the box carefully … and then read all of the instructions inside the box !


With regard to the issue of Carbon Monoxide (CO) Poisoning in Ireland … Statistics Gathering is not reliable.  National Legislation concerning the installation of Carbon Monoxide Detectors in buildings should have been introduced many years ago … but this has not yet happened.  Furthermore … don’t hold your breath waiting for this much-needed legislation.  Based on past performance, technical and administrative officials in our relevant authority having jurisdiction, i.e. the Department of Environment, Heritage & Local Government (DEHLG), will prefer to wait before acting until similar legislation is introduced in Britain (England & Wales).


I will just describe what I have done in my own house … in the kitchen …

[Smoke Detectors are separately linked into a monitored security and fire warning system.]

In every room where a fuel burning / heat-producing appliance is located … a Carbon Monoxide (CO) Detector is installed.  In the kitchen, for example, the Detector is fixed on the wall … at about head height, when sitting down at a table (appropriate for the normal pattern of use there) … and at a distance of approximately 2 metres from the natural gas kitchen range.  Control of direct, natural ventilation to the appliance is active … meaning, it always receives attention.  The usual kitchen clutter, e.g. clothes ‘waiting’ for ironing, etc., is never allowed to cover or block the Detector.  Everybody in the house understands the purpose of this product.

Colour photograph showing a battery-operated Ei Electronics Carbon Monoxide (CO) Detector, Model Ei206D, fixed (tamper proof) to the kitchen wall. Two of the hanging decorative plates are from France and Turkey. As for the third plate ... does anyone remember the Willow Pattern ? Photograph taken by CJ Walsh. 2011-01-12. Click to enlarge.

Colour photograph showing a battery-operated Ei Electronics Carbon Monoxide (CO) Detector, Model Ei206D, fixed (tamper proof) to the kitchen wall. Two of the hanging decorative plates are from France and Turkey. As for the third plate ... does anyone remember the Willow Pattern ? Photograph taken by CJ Walsh. 2011-01-12. Click to enlarge.


About the performance of the Carbon Monoxide (CO) Detector in the event of a ‘real’ CO Leakage … I am comfortably assured, as I have known the EI Company in Shannon since the mid-1980’s.  At that time, I was the first architect in Ireland to install smoke detectors in any local authority housing scheme … and EI gave great technical back up and support, for which I am still very grateful.  I might add that those same smoke detectors were installed against the wishes of the local fire department.  A report on the whole test installation process was later presented, by Dr. M. Byrne, Engineering Manager of EI, to an International Fire Conference in Dublin.

The particular Carbon Monoxide (CO) Detector shown in the photograph above is a battery-operated Model Ei206D.  There are no heavy, smoke sealed fire-resisting doorsets in the house … so the sound level of the distinct alarm / warning signal [85 dB(A) minimum at 3 metres] is more than adequate.  A few years ago, this was an expensive item to buy !   Now, however, CO Detectors are widely available … and at a more reasonable price.

Very Importantly … Ei Electronics have also developed a range of products – Solutions for All – which are suitable for use by People with Activity Limitations


Harmful Health Effects Associated with Carbon Monoxide (CO) Inhalation … at low concentrations: fatigue in healthy people and chest pain in people with heart disease.  At higher concentrations: impaired vision and co-ordination; headaches; dizziness; confusion; nausea.  Can cause flu-like symptoms which clear up after leaving home.  Fatal at very high concentrations.  Acute effects are due to the formation of Carboxyhaemoglobin (COHb) in the blood, which inhibits oxygen intake.  At moderate concentrations: angina, impaired vision, and reduced brain function may result.  At higher concentrations: CO Exposure can be fatal.  Source: EPA, USA.


Health Service Executive (Ireland) Factsheet

January 2011

Carbon Monoxide (CO) Poisoning – A Guide for GP’s & Other Medical Professionals

Click the Link Above to read and/or download PDF File (375kb)




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2011 Will Be A Great Year ! But … Is It 2011 ??

Today’s date is 11 January, in the year 2011 AD (2011-01-11) … using the Gregorian Solar Calendar … a special day !   We know this well … or, rather, we think that we know this …

BUT … this year is also 1432 H … using the Islamic Lunar Calendar … and it began a few weeks ago, back in early December 2010 !   The ‘H’ after the date indicates that it is the ‘Hijri Calendar’ … based on the Qur’ân [Sûrah 9 (At-Tawba): Verses 36 & 37].  Its proper observance is a sacred duty for Muslims.  This is the official calendar for many countries in the Arab Gulf Region.

In Japan … this is the year 23, in the Era of Heisei (written as ‘Heisei 23’) … based on, and beginning with, the reign of the current Emperor Akihito.

In China … the Year of the Rabbit will begin on 3 February 2011 (2011-02-03) !


What a wonderful world we live in !




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DAC’s & An Bord Pleanála (Ireland) – Brief SDI Announcement

The following ‘Warrant of Appointment’ as a Specialist Consultant to the Board … was signed on 17 December 2010 by Mr. John O’Connor, Chairperson of the Board …

An Bord Pleanála

Building Control Acts, 1990 to 2007  |  Building Control Regulations, 1997 to 2009  |  Building Regulations, 1997 to 2008

An Bord Pleanála hereby appoints  C.J. Walsh – Sustainable Design International (SDI)  to:

     (a)  carry out Inspections in relation to appeals against decisions of Building Control Authorities for applications for a Disability Access Certificate (DAC) ;

     (b)  conduct Meetings convened by the Board under Article 34 of the Building Control Regulations, 1997 ;

     (c)  make Written Reports (including Recommendations) to the Board in relation to such appeals ;


     (d)  be an Authorized Person, for the purposes of Section 11 of the Building Control Act, 1990.



The Functions of the Board in Ireland are …

An Bord Pleanála (Irish) … established in 1977, under the Local Government (Planning and Development) Act of 1976 … is responsible for the determination of appeals and certain other matters under the Planning and Development Acts, 2000 to 2010 … and the determination of applications for Strategic Infrastructure Development, including major road and railway projects.  The Board is responsible for dealing with proposals for the compulsory acquisition of land by Local Authorities and other Agencies, under various legal enactments.  The Board also has functions to determine appeals under Water and Air Pollution Acts, and the Building Control Act.




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January 2011
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