media
Fixing ‘Priory Hall’ in Dublin – Practical Solutions Needed Now !
2011-10-18: A large ‘can of worms’ has recently been opened in Ireland …
For the last few days, including today, I have been listening intently to Joe Duffy on the RTE Radio ‘Liveline’ Programme at lunchtime. Joe is being very cautious because he cannot quite believe his ears … either about the unfolding harrowing events for occupants in ‘Priory Hall’, Donaghmede, Dublin 13 – a Private, Multi-Storey Apartment Development – or the tales and anecdotes about Irish Building Sites during the Celtic Tiger Years.
This will be of no consolation to anybody … but the big surprise, for me, is that there is so much public shock. ‘Priory Hall’ is the Tip of the Iceberg ! Ireland’s current dysfunctional approach to the development of Our(!) Built Environment … has been designed (for want of a better word) in a chaotic, haphazard and malevolent way … to end up in exactly the sort of mess which we are all now witnessing in North County Dublin.
Just to be clear … what has been happening in the Irish Construction Industry, during the boom years, has been happening for twenty years all over the country … more precisely, since the introduction of Legal National Building Regulations, with NO Effective Building Control, in 1991 … and, before that again, in those parts of this jurisdiction, outside of the major urban areas having Legal Building Bye-Laws, and Effective Building Control, i.e. mandatory inspections by competent local authority personnel at the foundation level and drainage level of all building sites … and, depending on the type of project, occasional or frequent inspections above ground level.
[ 1991: Statutory Instrument No.304 of 1991 - Building Control Act, 1990 (Commencement Order), 1991; Statutory Instrument No.305 of 1991 - Building Control Regulations, 1991; Statutory Instrument No.306 of 1991 - Building Regulations, 1991 ]
And the biggest joke of all … is that the sum of the many resources, both human and material, required to repair sub-standard construction throughout Ireland … will count as a positive contribution towards the economic indicator of GDP (Gross Domestic Product) ! FUBAR
.
Colour photograph showing 'Priory Hall' ... a private, multi-storey apartment development located in North County Dublin, Ireland. Click to enlarge.
.
PRACTICAL SOLUTIONS NEEDED NOW
What I have not been hearing from the radio, or reading in the newspapers, is practical solutions.
Lest there be any doubt … this is one of the professional services we provide at Sustainable Design International !
So … how do we fix Priory Hall as the situation now presents itself … in such a way that, as soon as it is practicable, a satisfactory level of long-term safety, protection, convenience and comfort will be provided for the occupants of Priory Hall … and the social wellbeing of the local community, there, can be restored.
Afterwards … we can worry about who’s responsible, and about the reasons for the many ‘system’ failures in Ireland.
.
FIXING ‘PRIORY HALL’ IN DUBLIN
The following list of practical suggestions … a simple roadmap … is addressed to the Owners and Occupants of Apartments in Priory Hall.
As they have a large vested interest in the problems of Priory Hall … either directly or indirectly … no assurances or undertakings should be accepted, on face value, from either Dublin City Council (DCC) or the Department of the Environment, Community & Local Government (DECLG) … or their representatives.
1. Informed Consent of Apartment Owners and Occupants
Demand that the Informed Consent of the Owner/Occupant of an Apartment is required, in writing, before any necessary Corrective/Repair/Refurbishment Works are carried out …
Informed Consent: Consent freely obtained – without threats or improper inducements – after appropriate disclosure to a person of relevant, adequate and easily assimilated information in a form and language understood by that person.
2. ‘As Constructed’ Drawings & Specification of Entire Development
If they exist … we’re on the way ! But, if they don’t exist … and they may not … demand that an ‘As Constructed’ Survey of the Entire Development be carried out immediately.
Demand to see a copy of the Detailed ‘As Constructed’ Drawings, and Specification, for the Entire Development.
CHECK the adequacy of the Detailed Drawings and Specification !
At this stage, remember … all of the emphasis must now be placed on actual construction … not on paperwork ! The ‘As Constructed’ Survey Drawings and Specification are only a means towards a satisfactory end … that’s all !!
3. Failures to Properly Comply with Current Building Regulation Requirements A to M (Second Schedule to Irish Building Regulations)
Demand to see a Detailed Schedule of the many failures to properly comply with current Building Regulation Requirements, i.e. Parts A to M in the Second Schedule to the Building Regulations, as amended.
Do not entertain, even for a moment, any discussion about past legal building regulation requirements, which were in force at the time of initial design or construction !
An important point to note ! The Guidance Texts in, for example, Technical Guidance Document B: ‘Fire Safety’ are merely that … GUIDANCE ! This guidance is not infallible … and in a few respects, is entirely inadequate … for example, when dealing with the structural performance of buildings during conditions of fire, and the ‘cooling phase’ immediately afterwards … and the fire evacuation of people with activity limitations, in which case the guidance actually ensures that fire evacuation is made extremely difficult, if not prevented altogether !
Do not be sucked in to any conversations about what is stated, or not stated, in the Technical Guidance Documents. This is irrelevant. The Law mandates proper compliance with the Requirements !
Some people may even attempt to quote from the Building Regulation Approved Documents for England & Wales. Just tell them to take a long jump off a short pier … suggest Howth Harbour !
Become very, very suspicious whenever there is a use of, or reference to, the term ‘Substantial Compliance’ !!
CHECK the adequacy of this Detailed Schedule ! And … ensure that it is Comprehensive !!
4. The Necessary Corrective/Repair/Refurbishment Works
Demand to see Full Detailed Information, in the form of annotated drawings and descriptive texts, etc., etc … on the exact nature, timetable and phasing of all of the Corrective/Repair/Refurbishment Works which are necessary to effectively solve the serious problems in the Development.
Beware of decorative solutions, which look good to a superficial visual inspection in ambient conditions … but don’t actually solve anything !
CHECK the adequacy of this Full Detailed Information !
5. Independent Technical Control of Construction Works
Demand only Category A Construction Execution of the necessary Corrective/Repair/Refurbishment Works …
Category A Construction Execution:
(a) Supervision of the works is exercised by appropriately qualified and experienced personnel from the principal construction organization ;
(b) Regular inspections, by appropriately qualified and experienced personnel familiar with the design and independent of the construction organization(s) … and other vested interests … are carried out to verify that the works are being executed in accordance with the design.
Demand receipt of a clear undertaking, in writing, that this will be the case … before any Corrective/Repair/Refurbishment Works commence.
And remember these words from the 2005 Final Report of the U.S. National Institute of Standards & Technology (NIST) on the 9-11 World Trade Center Tower Collapses …
” NIST urges state and local agencies to rigorously enforce building codes and standards since such enforcement is critical to ensure the expected level of safety. Unless they are complied with, the best codes and standards cannot protect occupants, emergency responders, or buildings.”
CHECK the adequacy of the Proposed Method of Independent Technical Control during execution of the Corrective/Repair/Refurbishment Works !
6. Meeting & Discussion with Other Owners/Occupants
Do not act alone … meet the other Owners/Occupants, and discuss issues with them. Share and collate all available information together. Try to identify information gaps. If you do not understand something … ask !
When, and only when, you are happy … signal your Informed Consent that works should commence.
7. Commencement of Corrective/Repair/Refurbishment Works
Visit the Construction Site Office regularly … to show that you are taking a keen interest in what is happening. Keep your eyes and ears wide open.
Expect that you will not be permitted to just wander around the Site. Construction Sites are one of the most hazardous ‘workplaces’ in this country !
CHECK the adequacy of the Independent Technical Control actually being undertaken.
Demand to be updated, regularly, and at the very least on the progress of Corrective/Repair/Refurbishment Works at your Apartment … in the Common Areas of your Block … and throughout the full extent of the Approach Routes to your Block Entrances and Exits.
.
.
Advisory Note: Should you, or the Residents’ Committee of your Building or Development, be concerned about any matter discussed in this Post … please contact C.J. Walsh by e-mail: cjwalsh@sustainable-design.ie or by phone: (01) 8386078 / +353 1 8386078.
.
.
END (for now, but to be continued soon !)
10 Years After 9-11 … Are Our Buildings & Firefighters Safer ??
2011-09-11: From the beginning of the past week, news media (printed and on-line), and the television and radio schedules have all been full of articles, stories, opinions, and interpretative and speculative pieces about the 9-11 World Trade Center (WTC) Incident in New York, and its tragic aftermath. Today is the 10th Anniversary … a long ten years since that sunny Tuesday morning in Manhattan !
BUT … is anybody out there asking the questions: “Are Our Buildings Safer ?” … and … “Are Our Firefighters Safer ?” AND … if you do ask those questions … are you able to distinguish between solid, reliable information and ‘spin’ ?
So many Irish people, and people of Irish descent, were directly involved in this traumatic event … working inside the WTC offices, as stockbrokers … or outside, as maintenance personnel, or firefighters, policemen and women, or as members of the emergency medical services …
Colour photograph showing the thick cloud of toxic dust and debris spreading rapidly throughout lower Manhattan, and beyond, after the Second Tower Collapse (WTC 1/North Tower) just before 10.30 hrs (local time) on the morning of 11 September 2001. Earlier, seismic sensors located 160 Km away had recorded the time and intensity of the First Tower Collapse (WTC 2/South Tower) at 09.59 hrs (local time). Click to enlarge.
.
REALPOLITIK
The previous post about the United Nations Gaza Flotilla Report, I hope, created an uncertainty in your mind … a worrying thought regarding political interference and the negative, and very often, destructive influence of vested interests … which is a necessary frame of mind to have, also, for an essential discussion – on the 10th Anniversary of the 9-11 WTC Incident – about the Safety of Our Buildings, particularly High-Rise Buildings, Iconic Buildings, and those Buildings having a Critical Function and/or an Innovative Design … and the Safety of Our Firefighters.
By ‘Our Buildings’ … I don’t just mean buildings in Ireland, or Europe … I mean buildings on every continent of our small planet. And … such a discussion must be trans-disciplinary, involving the use of simple language only … because it is necessary for each discipline to clearly understand what the others are saying (this rarely happens !) … and the discussion must also be transparent to, and be easily assimilated by, the general population in all of our societies. And by ‘Our Firefighters’ … I mean firefighters worldwide.
Concerning the Gaza Flotilla Report … we could ask …
- Would the Findings and Recommendations have been different … if there had been 4 independent and obviously impartial people on the Panel of Inquiry instead ? The answer is … yes, of course ! And …
- Why did UN Secretary-General Ban Ki-moon nominate President Álvaro Uribe (Vice-Chair), an ‘ultra’ rightwing politician from Columbia … and Mr. Joseph Ciechanover Itzhar, an Israeli, to serve on the Panel ? I will leave you to answer that for yourself …
The important point I wish to make is that the community of International Fire Science and Engineering – just like every other ‘human’ community – is not immune from these sorts of malevolent influences !
.
Colour photograph showing advanced clean up operations at the World Trade Center Complex after 11 September 2001. Fires continued to smoulder for weeks after the Incident. Click to enlarge.
.
LONG-TERM ENVIRONMENTAL IMPACTS OF 9-11
Just five weeks after the 9-11 World Trade Center (WTC) Incident in New York … I found myself in Manhattan for the purpose of making an important presentation to a conference which was taking place not far from Madison Square Garden … while staying Down-Town in Battery Park City, at an apartment within the Security Zone. Yes, I was worried and fearful before going … but …
Environmental Impact: Any effect caused by a given activity on the environment, including human health, safety and welfare, flora, fauna, soil, air, water, and especially representative samples of natural ecosystems, climate, landscape and historical monuments or other physical structures, or the interactions among these factors; it also includes effects on accessibility, cultural heritage or socio-economic conditions resulting from alterations to those factors.
On first arriving in the city, by taxi from Kennedy Airport … I witnessed, at first hand, the racist hostility of a policeman towards our coloured Asian driver, who had simply asked about the procedure to pass through the Security Zone Boundary. Later, walking near the WTC Site, I would encounter the ‘macho’ behaviour of many National Guardsmen on security duty.
At the conference, I met a person who was literally unable to speak – could not even bear to talk about – the 9-11 Incident.
Everywhere south of Canal Street was in a terrible, horrific condition.
The weather, fortunately, had remained generally very good … sunny, with a light breeze coming in from the sea. Then, unexpectedly, one day towards the end of my stay … the sky was overcast and the air stood still … in lower Manhattan, it assaulted my eyes, nose and the back of my throat. Many times, during that particular day, I retched … but could not vomit ! Yet, a representative of the U.S. EPA (Environmental Protection Agency) announced that there was no problem with air quality ! Meanwhile, in Mid-Town, everything ‘appeared’ normal.
10 Years Afterwards … people, communities and the country (USA) are all still suffering … physically, mentally and psychologically … from the 9-11 WTC Incident … unable to ask for help, or perhaps, too proud or ashamed to speak up.
September 2001 – World Health Organization
WHO: How to Address Psychosocial Reactions to Catastrophe
Click the Link Above to read and/or download PDF File (12.5 kb)
.
10 YEARS AFTER 9-11 – ARE OUR BUILDINGS & FIREFIGHTERS SAFER ?
Or to put it in a more technical way … how are the Critical Recommendations contained in the 2005 & 2008 NIST(USA) Reports on the 9-11 WTC Buildings 1, 2 & 7 Collapses being implemented ? And, what is the quality of that implementation ?
At this time, two years ago … I asked …
- Why are so many Key Institutions and Organizations in the International Building Sector still desperately trying to ignore and/or deny the Recommendations in those 2 NIST Reports ?
- Why have National Building and Fire Codes/Regulations and Standards not yet been revised to respond, properly and satisfactorily, to the NIST Recommendations ?
- Why can we not yet use All Lifts (Elevators) in a Building during a fire incident ? Why are Lift (Elevator) Manufacturers still actively resisting this necessary change ?
.
Colour image showing an Ostrich with its Head in the Sand ... an accurate description of the International 'Technical' Reaction to the 9-11 WTC Incident ... "it never happened" ... or "it was a unique event, and it will never happen again" ... or "this unusual event only has implications for very, very, very tall buildings" ... blah, blah, blah !!
.
The answers to the questions are NO … and NO … minor revisions (tinkering at the edges) have been made to Codes/Regulations & Standards in some countries … and, generally, progress on implementing the NIST Recommendations is proving to be very slow … too slow ! Most surprisingly, no revisions have been made to Codes/Regulations & Standards in many countries.
To illustrate tinkering at the edges … refer to the USA’s International Building Code (2012 Edition) … which, despite its grandiose title, is really just another of the USA’s National Model Building Codes … and check out this very disappointing Article: ‘Evolution of Building Code Requirements in a Post 9/11 World’, by David Drengenberg and Gene Corley, in the recently published Special Issue III (2011) of the Council on Tall Buildings and Urban Habitat (CTBUH) Journal … which is available at http://www.ctbuh.org/
.
Progress at the National Fire Protection Association (NFPA), in the USA, is a little more apparent … but still, far too little and far too slow. Check out this recent Special 9-11 Report: ‘A Decade of Difference’, by Fred Durso Jr … on the NFPA WebSite … http://www.nfpa.org/publicJournalDetail.asp?categoryID=2248&itemID=53000&src=NFPAJournal …
And … released earlier this year, NFPA’s Third Needs Assessment of the U.S. Fire Service has identified ‘areas of ongoing concern’ !!
.
To Be Continued …
.
.
END
A More Balanced Presentation of Recent UN Gaza Flotilla Report
2011-09-05: Something is seriously wrong when it is stated in an official United Nations (UN) Report that any aspect of the Gaza Blockade by Israel is legal, under International Law.
Colour photograph showing the MV Mavi Marmara aid-carrying ship leaving the port of Antalya, in Southern Turkey ... on 22 May 2010 ... for Gaza, in Palestine.
.
On 2 August 2010 … UN Secretary-General, Mr. Ban Ki-moon, established a Panel of Inquiry to report on the 31 May 2010 Gaza Flotilla Incident in the International Waters of the Mediterranean Sea. The Panel Team consisted of 4 Members …
- Sir Geoffrey Palmer, Chair ;
- President Álvaro Uribe, Vice-Chair ;
- Mr. Joseph Ciechanover Itzhar ; and
- Mr. Süleyman Özdem Sanberk.
The Panel’s Report was released by the United Nations last Friday, 2 September 2011 … and can be downloaded from the following address … http://www.un.org/News/dh/infocus/middle_east/Gaza_Flotilla_Panel_Report.pdf
The Findings and Recommendations contained in the Panel’s Report have been widely covered since then, at national and international levels, in the various news media.
Colour photograph showing the 2010 Gaza Flotilla Panel of Inquiry Team ... Mr. Süleyman Özdem Sanberk, Sir Geoffrey Palmer, President Álvaro Uribe and Mr. Joseph Ciechanover Itzhar ... with UN Secretary-General, Mr. Ban Ki-moon, in the centre. (AP Photo/Mary Altaffer)
.
For a More Balanced Presentation of the Recent UN Gaza Flotilla Report, however, the following short statement by Mr. Sanberk, a graduate of the Law Faculty at Istanbul University and former Turkish Ambassador, must be reproduced – in full – and widely circulated.
Mr. Sanberk’s Statement can be viewed on Page 105 (the last page !) of the Report …
” I hereby register my disagreement with the Chairmanship on the following issues contained in the report:
- The question of the legality of the blockade imposed on Gaza by Israel ;
- The actions of the flotilla ;
- Naval blockades in general ;
- Appendix: The applicable International legal principles.
This, for the following reasons:
- On the legal aspect of the blockade, Turkey and Israel have submitted two opposing arguments. International legal authorities are divided on the matter since it is unprecedented, highly complex and the legal framework lacks codification. However, the Chairmanship and its report fully associated itself with Israel and categorically dismissed the views of the other, despite the fact that the legal arguments presented by Turkey have been supported by the vast majority of the International Community. Common sense and conscience dictate that the blockade is unlawful.
- Also the UN Human Rights Council concluded that the blockade was unlawful. The Report of the Human Rights Council Fact Finding Mission received widespread approval from the member states.
- Freedom and safety of navigation on the high seas is a universally accepted rule of international law. There can be no exception from this long-standing principle unless there is a universal convergence of views.
- The intentions of the participants in the International Humanitarian Convoy were humanitarian, reflecting the concerns of the vast majority of the International Community. They came under attack in international waters. They resisted for their own protection. Nine civilians were killed and many others were injured by the Israeli soldiers. One of the victims is still in a coma. The evidence confirms that at least some of the victims had been killed deliberately.
- The wording in the report is not satisfactory in describing the actual extent of the atrocities that the victims have been subjected to. This includes the scope of the maltreatment suffered by the passengers in the hands of Israeli soldiers and officials.
In view of the above, I reject and dissociate myself from the relevant parts and paragraphs of the report, as reflected in paragraphs ii, iv, v, vii of the findings contained in the summary of the report and paragraphs ii, iv, v, vii, viii and ix of the recommendations contained in the same text.”
.
.
END
Ireland’s Corrupt & Dysfunctional National Economic Governance !
2011-05-31: Further to my earlier Post, dated 22 December 2010 …
1. Social & Economic Environments in Ireland ?
It has been a hectic few weeks here in Ireland … with successful visits to our country by Queen Elizabeth II of England and President Barack O’Bama(!) of the United States of America … not at the same time, of course … and, lest we ever forget, the Leinster Rugby Team winning the Heineken Cup in Cardiff … and the Munster Rugby Team then beating Leinster, a week later, to win the Magner’s League Final in Limerick. It will take us a month of Sundays to recover !
It is slowly dawning on people in Ireland, however, that the Economic Environment is not the same as the Social Environment, which we are discovering is still resilient, robust, warm, vital and healthy. As for our miserable Economic Environment … sin scéal eile (that’s another story) … please see #2 below.
Social Environment: The complex network of real and virtual human interaction – at a communal or larger group level – which operates for reasons of tradition, culture, business, pleasure, information exchange, institutional organization, legal procedure, governance, human betterment, social progress and spiritual enlightenment, etc.
The Social Environment shapes, binds together, and directs the future development of the Built and Virtual Environments.
Built Environment: Anywhere there is, or has been, a man-made or wrought (worked) intervention by humans in the Natural Environment, e.g. cities, towns, villages, rural settlements, service utilities, transport systems, roads, bridges, tunnels, and cultivated lands, lakes, rivers, coasts, seas, etc … including the Virtual Environment.
Economic Environment: The intricate web of real and virtual human commercial activity – operating at micro and macro-economic levels – which facilitates, supports, but sometimes hampers or disrupts, human interaction in the Social Environment.
These are important distinctions !
.
2. Ireland’s National Economic Governance ?
In Ireland, a big deal has been made of losing our National Economic Sovereignty.
BUT … on 19 April 2011 … the Report of the Commission of Investigation into the Banking Sector in Ireland was published … ‘Misjudging Risk: Causes of the Systemic Banking Crisis in Ireland’. This document was prepared by Mr. Peter Nyberg, a Finnish Economist … and sole member of the Commission.
Immediately, it should be pointed out that this is just one report … in a series of reports purporting to thoroughly examine separate aspects of the Economic Catastrophe which befell Ireland in the period leading up to and during 2008. The intention of the Irish Government, at the time that these Investigations were established, was to obscure … as much as possible … the Big Picture of a Completely Corrupt & Dysfunctional System of Irish Economic Governance. Nobody saw anything … nobody heard anything … nobody knew anything !!
In order to protect the Guilty, the Incompetent, and the Inept … individuals are typically not named in such Investigation Reports. We - the Citizens of Ireland – are therefore not in a position to clearly identify these ‘mothers’ … as they engage in an elitist game of musical chairs around the boardrooms and senior management levels of our national institutions.
The following extract from the 2011 Nyberg Report … will give you a small, and very mild, flavour of what was happening during the Celtic Tiger Years. Please forgive the length of the extract … but try to stick with it. You must understand.
2011 Nyberg Report
‘Misjudging Risk: Causes of the Systemic Banking Crisis in Ireland’
Chapter 5 – Findings & Final Considerations
5.1 Findings – General
5.1.1 The Report concentrates, as its Terms of Reference require, on explaining the reasons specifically for the Irish banking crisis. However, it is useful to keep in mind that this crisis cannot be seen in isolation from what was happening elsewhere. It appears, at least on the face of it, that many of the problems and failings in Irish banks and public institutions were quite similar to those in other countries.
5.1.2 For instance, Irish banks compared their policies and achievements with peer groups containing well regarded banks in the UK and the EU. Risk management systems and remuneration practices were often adopted from abroad. Judging from results, similar problems, as in Ireland, arose in implementing them in a manner consistent with prudent credit policies. The relatively greater losses seen in Ireland may thus be seen as a consequence of somewhat greater abandon in accessing wholesale funding and in lending to domestic property than in other countries. Thus, there is a difference in degree rather than in concept.
5.1.3 Similarly, central banks and regulators abroad generally were almost as unsuspecting of growing financial fragility as their Irish counterparts. The method of regulation or the number of available macro-economists does not generally seem to have made a great deal of difference. The same seems true of auditors, rating agencies, analysts and investors, most of whom remained calm and optimistic until the crisis actually broke. Internal investigations in the IMF also indicate a widespread lack of understanding and clear communication of the accumulating risks by that organisation. There were incentives to conform with prevailing views, even in cases where proper analysis would have identified growing risk.
5.1.4 The fact that Ireland was not special does not, of course, account for or diminish the failures in the performance of the people in private and public positions responsible for financial stability and prudent banking. It does, however, put the many undoubted failings found by the Commission into perspective. Regardless, it indicates that the problems experienced in Ireland in the 2000’s have a wider relevance, as do any suggestions on how to prevent similar things from easily happening again.
5.2 Findings – Banks
Business Models & Strategies
5.2.1 Responding to increased competition and pressure for increased earnings, banks set aggressive targets for profit growth. In many cases, this drive for growth really implied a partial change in business model and strategy without the corresponding necessary strengthening of governance, procedures and practices. This was accepted partly because future economic developments were trusted to remain benign in Ireland as they already had been for several years. Comfort was also taken from peer bank practices and the lack of concern among authorities, market participants and observers. The particular characteristics of the property and funding markets were not taken into account.
5.2.2 In practice, Anglo Irish Bank (Anglo) was a monoline bank providing rapid but not cheap financing to a number of long-standing customers mainly in the commercial property market; sales and customer retention were important drivers of activity. Irish Nationwide Building Society’s (INBS) business model was unique and different to those of any of the other covered banks as it was concentrated primarily on speculative site finance, which proved initially to be very profitable in a rising property market. The model was risky, however, and risk mitigation primarily involved selecting trusted and previously successful customers. The business models of the other covered banks were more diversified, but during the Period most of them escalated their financing of commercial property in order to achieve profit growth. While IL&P remained concentrated on mortgage lending, it was increasingly funded by the wholesale markets.
Governance & Procedures
5.2.3 The primary problem with governance in the majority of the covered banks was not that it was lacking or poorly structured but that, over time, it changed as controls gradually weakened to allow increased growth. In some cases, management information systems were weak and did not give managers and the board meaningful or complete information. In particular, inadequate consolidation and categorisation of lending sometimes resulted in an incomplete picture of total or type of property exposures. In some of the bigger banks, the embedded internal divisional structures made group oversight difficult. The INBS model was atypical; the Society lacked a number of formal functions usually considered necessary in banks and, in addition, documentation was substandard.
5.2.4 On boards, there appears to often have existed a collegiate and consensual style with little serious challenge or debate. Among Non-Executive Directors (NED), it appears that the banking knowledge and expertise necessary to assess the lending and funding risks inherent in bank business models was insufficient. They were therefore formally independent but, in practice, highly reliant on the knowledge, openness and ability of bank management. In particular many NEDs, but also a number of senior management, seem to have believed that the existence of formal policies, structures and procedures were, on their own, sufficient for the prudent management of the business. As they came to rely more on sophisticated models, partly in consequence of the introduction of Basle II, many of the basics were neglected. It appears that senior management and boards did not appreciate how general growth targets affected operations lower down in the organisation.
5.2.5 In Anglo, some board members had significant shareholdings in the bank which indicates that they had particularly full trust in the operations and growth goals of the bank.
Remuneration
5.2.6 Financial incentives, while not the major cause of the crisis, likely contributed to the rapid expansion of bank lending since the incentives did not sufficiently stress modifiers for risk. There are, however, also other important motivating factors which must be taken into account when assessing the behaviour of individuals.
Lending & Credit
5.2.7 Lending growth was substantial in all covered banks and was largely concentrated in the property sector. In order to facilitate growth and make banks more competitive, credit and lending policies gradually became more relaxed and were frequently ignored or bypassed with exceptions to policy becoming commonplace. Furthermore, sector limits and individual exposure limits, where they existed, were regularly exceeded.
5.2.8 Real estate valuations in a rising property market created a ‘confirmation bias’ and frequently went unchallenged in the credit functions. The practice of equity release reduced the collateral buffers held by the banks and increased their risks accordingly.
Funding, Liquidity & Capital
5.2.9 On joining the EuroZone, Irish banks gained increased access to wholesale funding at a relatively low cost. As retail and corporate deposits were not sufficient to fund lending growth, wholesale funding enabled the banks to respond to competition and to grow balance sheets and earnings at a pace that banks believed would protect their independence and market share.
5.2.10 Treasury operations, charged with the balanced and prudent funding of asset growth, were also profit centres. This involved an inherent conflict as the use of cheaper short term funding frequently increased Treasury’s profitability at the expense of longer term funding stability.
5.2.11 There were significant increases in the loan-to-deposit ratios and in wholesale funding-to-total funding ratios. Furthermore, risks associated with wholesale funding were not fully recognised or understood in many cases. Banks consistently assumed that the uninterrupted and unlimited access to wholesale funding, at a low or reasonable cost, would remain. They also believed that the option of securitising eligible portions of their portfolio would always be possible.
Risk Management
5.2.12 Risk management structures proved largely ineffective in prudently managing and controlling rapid growth. As effective structures would have made high volume targets difficult to achieve, banks allowed their effectiveness to erode over time. There was also insufficient understanding or acknowledgement of the risks associated with the adopted business strategies or the sector concentrations. With easy access to funding, there was little effort by or incentive for the banks to diversify their property risks through measures such as syndications or loan selldown. Furthermore, there was a general belief among bankers and others in political, media and academic circles (including some very influential commentators) that there would be, at worst, a soft landing.
Regulation as Seen by Banks
5.2.13 Banks, clearly somewhat in agreement with the Financial Regulator (FR) itself, believed that they were in a better position than the FR to judge and decide upon what was most prudent in their own operations. This belief was underpinned by the fact that regulation was ‘light touch’ and seemed to stress consumer issues rather than prudential issues. There was almost an element of the FR being ‘fobbed off’ by banks that had particularly full confidence in the quality and sophistication of their models and systems. Subject to this, the FR and its communications were normally, however, accorded proper formal respect.
5.2.14 There were numerous instances of non-compliance with respect to banking regulations and guidelines which went unsanctioned by the FR. In some cases (Anglo and INBS), where the FR did raise concerns, they sometimes led to little real change and there was little follow through by the FR. Bank management drew undeserved comfort from the acquiescence of the FR in relation to this non-compliance.
5.2.15 There existed a loop of excessive reliance between the various authorities on the one hand and between accounting standards, internal risk structures, credit grading systems and board sub-committees on the other. This systemic failure resulted in the dangers inherent in the business models remaining undetected until it was much too late.
5.3 Findings – Authorities
5.3.1 The speed and severity of the crisis was exacerbated by worldwide economic events. The main reason, however, was the unhindered expansion of the property bubble financed by the banks using wholesale market funding. Government policies and pronouncements tended to support this expansion. The attendant risks went undetected or were at least seriously misjudged by the authorities whose actions and warnings were modest and insufficient.
5.3.2 The Irish authorities had the data required to arouse suspicion about trends in the property and financial markets. The relaxed attitude of the authorities was therefore the result of either a failure to understand the data or not being able to evaluate and analyse the implications correctly. Both macro-economic and banking data could, particularly when combined, have provided the authorities with an understanding of what was going on. The Financial Stability Reports (FSR) provided information on individual perceived risks but, in the Commission’s view, the data should have raised greater suspicions by end-2005 or, at the latest, by 2006.
The Financial Regulator
5.3.3 Provided the appropriate structures and processes were in place, the FR’s approach was to trust bank leadership to make proper and prudent decisions. However, even when problems were identified and remarked upon, the FR did not subsequently ensure that sufficient corrective action was taken. Thus, even insightful and critical investigation reports tended to have little impact on banking practices. Furthermore, readily available information on, for instance, sector or borrower concentrations was not sufficiently critically analysed by the FR. Even if it were accepted that the FR was significantly under-resourced throughout the Period, this would not explain why available information was not acted upon.
5.3.4 It seems remarkable that the FR in practice accepted the severe governance problems in INBS. Allowing this bank to continue operations without major reforms or sanctions must, on the part of the FR, have reflected either a reluctance to pursue legal action or a profound trust in bank management and the board. Similarly, the rapid and concentrated lending growth in Anglo, and later in other banks, did not lead to regulatory action, with reliance being placed on management assurances that all was basically well. The FR continued to accept these assurances, even after the Guarantee decision in late 2008.
5.3.5 The Commission is aware of the view that the FR did not have sufficient powers to intervene. This view is not persuasive given that the FR could have acted in concert with the Central Bank (CB) and, ideally though perhaps unrealistically, with Government support. The real problem was not lack of powers but lack of scepticism and the appetite to prosecute challenges.
The Central Bank
5.3.6 The CB chose to rely on the FR appropriately handling individual bank stability issues, much as the FR in turn chose to trust bank leadership. By implication, unless there were problems in the individual banks, there could not be major stability issues in the system as a whole. The Financial Stability Report (FSR) was constrained to present benign conclusions with a number of almost routine warnings voiced in the text itself. Simultaneously, macro-economic data signalling the emergence of the two key risks – growing dependence on foreign funding and the concentration of bank lending in the property sector – did not appear to have caused acute concern.
5.3.7 At least at policy level, the CB seems not to have sufficiently appreciated the possibility that, while each bank was following a strategy that made sense, in the aggregate, when followed by all banks, this strategy could have serious consequences for overall financial stability. This was a classic macro-economic fallacy that must have been recognised in the CB and it remains unclear why it was not appreciated at senior levels there. However, there are signs that a hierarchical culture, with elements of self-censorship at various levels, developed in the CB. Of course, this eventually made it even harder to address the increasing instabilities in the financial market.
5.3.8 The Commission is aware of but disagrees with the view that the CB would not have been entitled to intervene to address stability issues concerning individual banks. If the CB management had identified or given sufficient weight to macro-economic vulnerabilities, it could and should have initiated discussions with the FR to ensure a deeper analysis of individual banks’ regulatory returns. However, as neither institution suspected any significant problems this does not appear to have been done.
The Department of Finance
5.3.9 The Department of Finance (DoF) did not, despite its mandate, see itself as concretely involved in financial stability issues; it also did not have the requisite professional staff for this. There were regular formal contacts with the FR (via the approval process for its budget) and somewhat more frequently with the CB, both in practice responsible for operational stability assessments. The DoF saw itself as preparing legislation to be implemented by the other authorities, but appears to have avoided addressing other financial market issues unless brought to the table by the FR or the CB (for instance, Credit Union issues during the Period). This apparently was due to their legally independent status. The Commission could find no evidence that the DoF formally tried to influence the FR in its work. The DoF also did not make any efforts to strengthen its own financial market expertise despite crisis management exercises in the EU having shown a need for it among finance ministries.
5.3.10 Had the DoF taken a greater interest in financial market issues early on, preparations for dealing with the financial crisis would have been more comprehensive. It is well documented that the DoF consistently, though not forcefully enough, supported a less expansive fiscal policy, particularly regarding property market incentives. It also appears that worries about the developing financial situation were expressed internally from time to time by some DoF staff. However, nothing came of this as the CB and FR were seen as responsible for financial stability.
The Guarantee Decision
5.3.11 From mid-2007 onwards, co-operation improved between the key institutions involved and some important preparatory crisis management work was undertaken. However, the view that the only relevant problem was a threat to the liquidity position of the banks remained unchallenged throughout. There appears to have been no fears and, at most, a modest discussion on possible underlying acute solvency problems. This is true of the banks themselves, as well as of the authorities.
5.3.12 The discussions for alternative measures before and on September 29, 2008, were conducted on the basis of very deficient information. The authorities were apparently convinced that bank solvency issues were not pressing or significant, as were the banks themselves, and that it therefore would be possible to resolve the acute liquidity issue. Furthermore, the liquidity problems appear to have been seen as temporary only and related mainly to international developments. If more relevant information on and analysis of the underlying position of some of the banks had been available, discussions and policy recommendations may have been very different.
5.3.13 Given the information provided, the Commission understands the Government’s decision to provide a broad guarantee for the banks; if no major solvency problems were expected the Guarantee would not have to be called upon. However, given the size of the amounts involved as well as the domestic and global uncertainties, it could have been useful to access available temporary funding to gain time to examine more thoroughly the advantages and disadvantages of alternative approaches. These could have included limiting the scope and duration of the Guarantee. However, there were concerns that the market would not have acted positively to such a delay at the time.
5.3.14 The lack of information on bank exposures among the Authorities over time had profound implications for the decision actually taken. Had better information on exposures and thus the risk of future impairments already been readily available in earlier years, government advisors could have suggested, even much before September 2008, that such banks with reasonably foreseeable problems should be taken into public administration immediately and gradually closed or restructured. Management could have been changed to eliminate further lending and risk-taking. Banks could, alternatively, have been required to raise additional capital from the markets while it could be accessed; markets still were open for this. However, authorities continued to believe that banks did not have excessive property exposure and even outside evaluators only gradually came to a different view. As it turned out, no bank restructuring was contemplated until several months after the Guarantee when plans announced by the Government on a piecemeal basis had proved to be insufficient, thus reducing the credibility of the Irish authorities.
5.3.15 Crisis management in Ireland, therefore, was rendered less than fully effective by long-standing insufficient appreciation of bank exposures on the part of all the authorities. Decision makers and their various advisors, in autumn 2008, still mainly shared the common view that the banks were, and would remain, solvent.
5.4 Why Did It All Come Together ?
5.4.1 It has been argued in this Report that during the Period the paradigm of efficient financial markets was widely accepted, particularly among developed nations. Believers in a naïve version of this paradigm would tend to assume that developments in the financial markets, almost by definition, could not be seriously flawed from a systemic point of view. Furthermore, they would also tend to assume that regulation of the financial markets would reduce innovation and efficiency without improving stability; less and lighter regulation was therefore better. Since there was widespread international belief in this paradigm, the international nature of the financial crisis, as well as the general unpreparedness of banks and authorities, is easier to understand.
5.4.2 To the extent that this paradigm, in its naïve version, had become widely trusted among Irish financial professionals in private and public institutions, such an assumption may have been made both across institutions and within institutions (strengthened through groupthink). These assumptions in turn would have led, in the absence of strong and specific proof, to a belief that virtually any market feature or development was benign almost by definition, whether in the property market, the financial market or, indeed, in any individual bank. In effect, if it was financed by somebody, it must almost by definition be sound.
5.4.3 However, it is the belief of the Commission that stronger, irrational forces were also present. The widespread consensus as well as the confidence, until the very last moment in late 2008, that everything would end relatively well points to the existence of a national speculative mania in Ireland during the Period, centred on the sale and acquisition of property. Warning signs were ignored as continuing economic stability was confidently assumed. Traditional values and practices were seen as less relevant in the new financial order. When the mania ended, participants had difficulty in accepting blame for their own part in it since everything had seemed so normal and acceptable at the time.
5.4.4 Given this background, it is easier to understand why developing and clearly visible problems in the Irish banks and markets could remain ignored by so many. It also helps explain why banks so readily crowded into speculative property lending, which appeared to be a certain road to success (herding on the mania). It makes it easier also to understand why the authorities, despite being provided with information on increasing fragilities in the banking system, could remain complacent for so long. Finally, it goes some way towards explaining why the crisis, despite being the culmination of a number of clearly unsustainable developments, was so totally and generally unexpected almost up to the very last minute.
5.4.5 The general acceptance of the paradigm of efficient markets also throws light on why most international institutions, foreign analysts, rating agencies, lenders, authorities and commentators were as relaxed about Irish developments as people in Ireland themselves. It is argued that the long period of benign conditions in Ireland played a substantial role in convincing observers that developments were stable. Furthermore, if large numbers of people also believed in the naïve interpretation of the efficient financial markets paradigm, very few developments in the financial markets would appear unsound or imprudent to them anymore.
5.4.6 It may seem remarkable that people in Ireland (and elsewhere) with extensive experience in regulating and operating in financial markets may have accepted such fairly extreme assumptions for their daily work. It has been argued that various bandwagon effects (see Section 1.6 above) may have played an important role in this, as may the fact that international supervisory and banking peers abroad also accepted these assumptions at least to some degree.
5.4.7 Ireland’s systemic banking crisis would have been impossible without a widespread suspension of prudence and care by those responsible for bank management as well as by those charged with ensuring responsible financial conduct. Investors and other borrowers as well as bank executive management have an interest in doing deals with each other for profit and for glory; what went missing was prudence in ensuring that such deals were soundly based. Bank boards and public authorities, whose role it is to make it difficult for the dealmakers to go overboard, continued with their traditional work. However, their authority and, unfortunately, their vigilance as watchdogs were in decline. The stability of markets was becoming more dependent on bank management and their risk management systems.
5.4.8 The majority of bank executive management, despite their apparent superior technical knowledge of the business, chose to follow the new but unsustainable banking model. Lending was seen (and rewarded) as selling a loan or service rather than as acquiring a risky asset. Banks’ management and boards embraced a lending sales culture at the expense of prudence and risk management. This view then spread down through the ranks, partly through the effects of volume targets and bonus systems and partly through indoctrination, causing the massive run-up in risky assets.
5.4.9 The external watchdogs generally remained inactive as management’s new banking model was introduced and implemented. There was no strong external reaction when management prudence eroded within the Irish banking system, as evidenced by the very rapid growth in lending and wholesale funding. The Commission has not found any clear and documented cause for the simultaneous lack of action by various watchdog authorities; it can therefore offer only the partly hypothetical behavioural factors described earlier in this section.
5.5 Specific Irish Features
5.5.1 The Commission proposes that the crisis points towards some interesting features of how Irish society appears to have functioned during the period 2003 – 2009. It is considered that these features may be specific only to Ireland and, if present, they would further help explain why there was little recognition and even less prevention of the property mania in Ireland.
5.5.2 Firstly, there seems to have been little suspicion or doubt among Irish decision makers that the path being followed was the correct one. A great number of persons in very responsible management and watchdog positions insisted that, until the end, they had no idea that a serious and acute problem with lending and funding exposures in the banking system even existed. In the stated absence of this knowledge, little was done to prevent the crisis. This is true of politicians (whether in government or opposition), central bankers, regulators, department officials and bank board members as well as influential analysts in the media, academia and financial enterprises.
5.5.3 The Commission has been widely assured by bank management, non-executive board members and others that the problems in banks’ loan books came as a complete surprise. There is regret, incredulity and guilt among them at the lending and funding policies pursued and the lack, at the time, of any recognition of what was happening. The credibility of their assertions is increased by the fact that a number of them personally suffered substantial losses in the crisis, easily avoidable if advance warnings had been available and recognised.
5.5.4 This suggests to the Commission that, in the absence of a liquidity crisis at this time, things would have continued much as before in Ireland, at least for a time. The property market would have continued to expand, though at a slowing pace, and banks’ portfolios of property loans would have continued to grow. Therefore, banks would have had time to become even more dependent on market funding and even more exposed to the effect of any doubt regarding the value of their assets. At some point, financial markets would have realised the risks on the Irish banks’ balance sheets. While a soft landing always would have remained a possibility in principle, overall international experience with the bursting of property bubbles, the general lack of foresight as well as the scale of the exposures seems to argue against it.
5.5.5 Secondly, there was a conspicuous lack of timely critical debate and analysis by bank analysts within institutions and among the public at large. The complacent views of Government, other authorities, banks and their customers appear to have been very well aligned with each other. Public policy and discourse seems to have almost unanimously accepted and encouraged views and practices that later proved disastrous. Examples are not difficult to find; for instance, the pervasive assumption of continued growth, the failure to see growing indebtedness as a serious policy problem, the ‘soft landing’ scenario and, finally, an unwillingness to recognise the existence of long-standing problems in some banks. When alarms were finally sounded, they were too late for meaningful action; the problem loans were already on the banks’ books and were largely illiquid.
5.5.6 The very limited number of warning voices was largely ignored. Attempts by banking insiders during the Period to send cautionary signals to market participants about escalating property values were dismissed as ill informed and wrong. Doubters (the few that identified themselves as such to the Commission) in the main grew unsure over the years when nothing seemed to go wrong. It also appears that some stayed silent in part to avoid possible sanctions. The Commission suspects, on the basis of discussions held with a wide number of people, that there may have been a strong belief in Ireland that contrarians, non-team players, fractious observers and whistleblowers would be informally (though sometimes even publicly) sanctioned or ignored, regardless of the quality of their analysis or their place in organizations.
5.5.7 Thirdly, many institutions in the broader financial sector seem to have operated in silos. There appears to have been little appetite or opportunity for looking at ‘the bigger picture’ since, as related earlier, each part of that picture was ‘owned’ by different authorities or, within the banks, by specific departments. While clear divisions of responsibility are important, in Ireland such divisions appear to have reduced also the desire or (legalistically argued) the ability to co-operate effectively.
5.5.8 For organisational silos to work well there must either be strong and frank communication between their leaders or, alternatively, little interdependence between them. It is unclear which one of these, if any, was believed to operate. One possible consequence of this ‘silo think’ was that the DoF, discouraged from interfering in the work of the independent FR and CB, remained seriously underweight in professional financial expertise and engagement. The Commission considers it likely that the lack of overall analysis and responsibility in so many Irish public institutions may have allowed a number of warning signs to remain undetected. Indeed, overlapping interest is not necessarily a bad thing as long as responsibilities remain clearly differentiated.
5.5.9 Fourthly, adhering to either formal or traditional, often voluntary, constraints and limits on banking and finance, does not seem to have been greatly valued in Ireland during the Period. The wide acceptance of the new financial paradigm may have amplified any such tendency as it applies to the banking sector. The consequences for financial stability are, in any case, severe in the longer term.
5.5.10 Regulations, rules, procedures, constraints and sanctions exist primarily to prevent management and staff from going overboard during good times. The better and longer the good times are, the more important it is that these safeguards exist and are adhered to. If they do not exist, or are ignored, exposures can grow dramatically as confidence grows and risk is underestimated. The risk of systemic disturbances therefore increases greatly if political leaders and public institutions do not insist on these safeguards being consistently and efficiently followed. Therefore, any greater than average lack of willingness in Ireland to follow rules and constraints is likely to make for a more fragile financial system than elsewhere in the long run.
5.5.11 The Commission considers that it cannot have remained a secret from banking and audit professionals that time-honoured prudential limits and procedures were gradually falling into disuse, particularly in some banks. Examples and indications of serious governance and prudential problems were clearly available to professional observers, including the FR. Increases in credit concentration, loan size and volumes, as well as changes in funding structures, were not concealed. They could also have been inferred from macro-economic data. Information about ongoing and accelerating property speculation was common in everyday Irish life.
5.5.12 The Commission accepts that the new, widespread paradigm, as well as the mania in the Irish property market, could create strong pressures for conformity in all the institutions discussed in this Report. However, while this could explain such behaviour, it does not provide an excuse for those who conformed. Only a naïve and opportunistic interpretation of the paradigm, together with a lack of either relevant experience, training or historical knowledge, could possibly have argued for a major dismantling of the traditional prudential safeguards. History is replete with examples of what happens when bankers, authorities and others come to believe that ‘this time it’s different’.
5.5.13 The Commission therefore has reluctantly come to the conclusion that at least some of the financial market professionals at the time must have entertained private, undisclosed doubts on the sustainability of banks’ lending and funding policies. However, for various reasons ‘the dance had to go on’. Similarly, it seems likely that the public and private watchdogs remained less active than required, not only because they did not know, but also because it was not publicly acceptable, legally necessary or prudent to act at the time.
5.5.14 During much of the Period, Ireland was still seen as a success story that provided a large number of its inhabitants with self-esteem as well as rising incomes, wealth and welfare. Anybody seriously interfering with this process would expect to be publicly castigated as causing the very distress, loss and crisis that they would have been trying to prevent. Instead, by allowing the party and deal making to continue, management, investors and public and private watchdogs participated in its positive but temporary gifts.
5.5.15 That said, the Commission is not suggesting that financial professionals in Ireland consciously decided to let banks get into trouble. As indicated earlier, it is much more likely that professional suspicions were explained away or suppressed, in light of the new financial dogma and a long period of good times, in order not to appear fractious, unprofessional or alarmist among colleagues, superiors and others who were believed to possess equal or even superior knowledge.
5.6 Lessons to be Learned from the Irish Experience
5.6.1 As already noted above (Section 1.4), emergence of a systemic banking crisis requires that a number of important safeguards all become ineffective simultaneously. The likelihood of this is not large, since some part of society and the banking sector is likely to remain vigilant even if other parts do not. However, as has been seen in a number of countries and regions before, at times the unlikely occurs.
5.6.2 The Commission has, having extensively examined the most relevant available documentation as well as interviewed very many people involved in the run-up to the crisis, explained the crisis essentially as a consequence of applying a naïve version of the efficient market paradigm, supported by groupthink and herding. This helped create and strengthen a mania in the Irish property market. Professionals and non-professionals alike became convinced, and convinced each other, that financial markets were stable by themselves, despite historical evidence to the contrary. The implications of this conviction seemed to be in the immediate interest of the overwhelming part of Irish society. The resulting activity was something that, later on, seemed quite unsustainable, puzzling and contrary to prudential requirements and common sense.
5.6.3 The development of excess indebtedness and property market overheating appears to have been fairly common in many countries in recent years and decades. This Report contains a short indication of how a groupthink and herding mechanism could support a theory of recurring financial cycles. The Commission has detected signs of such a mechanism both within Irish banks and within Irish public authorities during the run-up to the crisis. This mechanism may have been particularly strong because of the widespread existence of a belief in self-regulating, efficient markets.
5.6.4 If this hypothesis is accepted, an important implication emerges. Because the real reason for the crisis is the spread of an ultimately irrational point of view, regulations and watchdog institutions cannot be counted on to be efficient preventers of a systemic crisis. As has been seen in Ireland and other countries, central bankers and regulators embraced much the same paradigm as the market participants and adapted their policies to their convictions. The result, as shown by the crisis itself, was that no effective brake on risk-taking existed for years. It does not appear wholly unfair to propose that this is what may happen also in the future if and when another new financial or banking paradigm appears. Many of the very reforms that recently have been undertaken, at short notice, to shore up the functioning of the present financial system could turn out, once again, to be ineffective.
5.6.5 Permanently improving financial stability therefore should perhaps, instead, be done in ways that do not necessarily demand the unfailing attention, prescience or vigilance of ministries, central banks or regulators. Arguably, the most important goal of such a system should be to directly reduce the likelihood of serious disturbances to the real economy. A number of suggestions have been made to primarily address this problem. They seem to have been made mostly by policy makers and practitioners; academic economists have often remained unconvinced by at least the more radical of these suggestions.
5.6.6 The prevalence of problem banks that are large in relation to both the economy and the sovereign (too big to fail and too big to save) suggests that measures limiting the size and growth of banks and the banking system in relation to the economy could be useful. One alternative, not widely supported due to its arbitrary nature, would be to directly set a limit on the absolute size of a bank’s balance sheet. Other alternatives, briefly discussed below, are indirect and would operate by raising the cost of expanding the (properly risk-weighted) balance sheet. Such alternatives include: a high and progressive minimum capital requirement (set nationally); limiting implicit government subsidies to certain bank activity clusters only; and raising the potential default costs for investors in banks. These alternatives can, of course, be combined.
5.6.7 Radically increasing the capital requirements of banks would reduce their vulnerability to both funding and solvency shocks. Since banks would need much more capital to operate, the resulting buffer of private capital would be larger in case of a default. Capital requirements could also be made progressive in relation to the size of the balance sheet. Since different countries would be able to support different-sized banks, such reform would have to be nationally determined. Competitiveness would be affected, creating pressure for an internationally agreed formula. As indicated by the discussions around Basel III, the issues of definition and of interaction with other prudential constraints are always significant. Problems of acceptance are likely to arise particularly in large countries able to support large (potentially problem) banks.
5.6.8 Banks are routinely provided with a number of indirect government subsidies. These include, inter alia: entry-limiting licensing requirements; monopoly on gathering retail deposits; access to central bank facilities; and the possibility of government assistance. Because such subsidies are designed to make the system more stable it would not be useful to eliminate them. What may prove feasible, however, is to delimit types of allowed funding and lending activities in a way that makes government assistance dependent on the type of banking license provided. This would limit the part of the banking system explicitly supported by the sovereign and increase ex ante the responsibility of private investors for the rest of the system. Such a separation would need some way of, additionally, severely limiting both ownership and funding links between different types of license holders. Competition issues would create pressure for international agreement on how various activities are defined and which may or may not be publicly assisted. Similar, though not identical, effects could be achieved through sufficiently divergent capital requirements for various asset classes. Nevertheless, if license groups are appropriately defined, much of the functionality of the present system could remain.
5.6.9 Accepting special restructuring regimes for financial enterprises would make it possible to address bad loans before the enterprise is insolvent. Introducing mandatory, collective action clauses for bank and sovereign bonds would reduce the supply of unsustainably cheap bank funding, as well as weaken any implicit demand on and credibility of sovereigns to protect bondholders. Both these features may be introduced more generally already as a result of the present crisis.
5.6.10 The costs to the economy of such reforms are undeniable; higher cost of credit (though mitigated by lower risk premia) and concentration of the banking business of large international enterprises to a smaller number of major international banks being the two most obvious. However, given the losses suffered through systemic banking crises over recent decades, this might be an acceptable price to pay for less systemic fragility and attendant resource misallocations. There is no free lunch and increased financial stability will always have costs. In the end, of course, the extent to which the present crisis causes a rethink on the basic model for maintaining a stable financial system will remain a very political decision with a major impact on important and influential financial institutions.
.
.
POSTSCRIPT
2011-10-16: Two days ago, on 14 October 2011, in Dublin … the Organization for Economic Co-Operation and Development (OECD) presented its latest Economic Survey of Ireland.
Becoming a Mature Independent National State, within a still developing system of shared sovereignty, balanced across all aspects of European Society … the European Union (EU) … must, sometimes, be a painful experience …
Organization for Economic Co-Operation and Development
OECD Economic Surveys – Ireland (October 2011)
OVERVIEW SUMMARY
The Irish Economy was hit by a severe crisis in 2008, after over a decade of strong growth that propelled Ireland to the fourth highest level of GDP per capita in the OECD. Initially growth was well founded on solid productivity increases. However, during a period of low-cost funding on international markets and low risk aversion globally, the expansion became increasingly reliant on a speculative housing bubble financed by lax bank lending standards and excessive credit expansion that collapsed in 2008 in the midst of the global economic and financial crisis. During the latter part of the boom, the acceleration of wages eroded international cost-competitiveness and the banking system became over-extended and, once the bubble burst, would have been insolvent without state support. Capital injections to help resolve the crisis have resulted in a sharply higher public debt. In the aftermath, households have been hit by wage cuts, job losses, tax increases and falling house prices, though living standards and perceptions of wellbeing remain high by international standards.
Since 2008, the government has carried out a very sizeable fiscal consolidation. This effort is continuing. The three-year adjustment programme with financial support from the International Monetary Fund (IMF) and the European Union (EU) is on track and has started to tackle the roots of the imbalances. Following comprehensive stress tests, the banking system has been recapitalised, but the banks still require liquidity support from the Euro System. Good progress is being made to cut the fiscal deficit, but more needs to be done. Against a challenging international backdrop of contagion risk and uncertainty about the policy of euro area governments on sovereign debt, financial-market sentiment towards Ireland worsened considerably but did improve somewhat during the summer. The crisis caused a sharp rise in joblessness and large numbers of young less-educated males remain unemployed. The risk is that joblessness becomes persistent, which could undermine the social consensus that is underpinning the economic and fiscal adjustment. A modest recovery is underway, driven by gains in competitiveness and increases in exports, but it comes with significant downside risks associated with market fears regarding financial stability in the Euro Area. While government gross debt as a share of GDP has reached one of the highest levels in the OECD area and official financial support remains indispensable in the near term, an orderly return towards a more balanced financial position is possible, provided that tight fiscal policies and wage restraint are in place sufficiently long. To increase the chances of success, the authorities need to continue vigorously implementing the measures required to complete the unwinding of imbalances, ensure that the burden is fairly shared and capitalise on the structural strengths of the Irish economy. These include its business-friendly environment, its flexible labour markets and a skilled labour force.
This Survey argues that the authorities should:
Persevere on the Path of Fiscal Consolidation
- Continue to fully comply with the conditions and targets of the EU-IMF Programme ;
- Reduce the budget deficit to below 3% of GDP by 2015 ;
- Reduce the budget deficit faster than required by the Programme to help regain credibility in financial markets if economic growth allows ;
- Focus spending restraint on public-sector efficiency, welfare reform and scaling back infrastructure projects ;
- Broaden the tax base by reducing tax expenditures and proceeding with the planned property taxes ;
- Strengthen the fiscal framework by focusing on the debt-to-GDP target to be met by a specified date; legislating multi-year budget plans; and introducing a nominal expenditure ceiling.
Exit from the Banking Crisis and Restore the Banking System to Health
- As financial market confidence returns, restrict the bank eligible liability guarantee scheme to a narrower range of liabilities, with fees that are commensurate to risk ;
- To help prevent future crises, focus supervision on a set of indicators including: a simple leverage ratio; loan-to-value ratio; loans-to-income ratio; and capital requirements linked to bank size. Also establish a credit register to prevent excessive exposures ;
- To prevent the recurrence of problems with regulatory forbearance, adopt a process where the breach of identified thresholds, such as excessive growth in overall lending, would accelerate a formal assessment of what, if any, corrective action may be required.
Prevent High Unemployment from Becoming Structural
- Engage the employment services more actively with job seekers, and require participation in relevant training and job search in return ;
- To promote return to work, relate unemployment benefits to unemployment duration ;
- Review the work incentive effects of other welfare benefits, especially housing allowances ;
- Better attune training programmes to labour market needs; in particular enlarge the set of trades covered by apprenticeships and temporarily close apprentice admission in construction trades ;
- Extend the duration of the current cut in employers’ social security contributions.
Further Improve Competitiveness in Order to Support Export-led Growth
- A further decline in unit labour cost is essential to support exports ;
- Enhance competition in the electricity sector by clearly separating generation, transmission, distribution and supply ;
- Focus feed-in electricity tariff support on the most cost-efficient renewable sources ;
- Introduce civil fines in competition law, so as to reduce incentives for anti-competitive behaviour ;
- To enhance the quality of education, systematically evaluate teachers’ and schools’ performance.
.
.
END
Situation in Libya – U.N. Security Council Resolution 1973 (2011)
2011-03-21: Around this time, in 2003, we were witnessing the First Christian Fundamentalist Crusade of the 21st Century (the so-called ‘Information Age’) … the Illegal Invasion of Iraq … payback time for the WTC Incident (9-11) in New York … and an excuse to plunder and loot the valuable oil and other assets belonging to an Independent, Sovereign State. What an ugly, unresolved mess it remains !
And yet … here they go again with Libya … the Rogue’s Gallery of the United States of America, Great Britain, France, Italy and Qatar … with the League of Arab States providing the necessary cover of respectability. How will this military intervention turn out ?
There is now, however, a U.N. Resolution. But … will the scope and terms of the Resolution be respected ? Judge for yourselves, as events unfold …
United Nations Security Council Resolution 1973 (2011)
17 March 2011 – 6498th Meeting
Click the Link Above to read and/or download PDF File (52kb)
.
Without any further delay … the present structure and legal framework of the United Nations must be revised, and updated, to meet the changed circumstances of the 21st Century.
Respect for International Law … Human and Social Rights for All … and Lasting Peace … are essential prerequisites for Sustainable Human & Social Development !
.
.
END
Landfill Fires & Contaminated Water Supplies – Join Some Dots ?
2011-02-23: With the blanket media coverage of the upcoming Irish General Election, which will be held on Friday next, 25 February 2011 … the following 2 Environmental Protection Agency (EPA) Press Releases concerning the ongoing Kerdiffstown Landfill Fire Incident in County Kildare … which were issued in quick succession on Friday afternoon last, 18 February 2011 … may not have received adequate public attention …
1. Friday 18th February 2011: Statement on Behalf of Co-Ordinating Group
Re: Kerdiffstown Fire
Date released: Feb 18 2011, 3:12 PM
Active firefighting has been wound down as brigades undertake a phased withdrawal from the Kerdiffstown landfill site near Naas. The fire, which flared up on 18 January 2011, was unprecedented in Ireland and it proved very challenging. Initial assessments indicate that, by comparison with international experience, the time taken to suppress the fire was relatively short – given its nature and the environment in which it took place. Fire brigades will maintain a precautionary watch on the site until the middle of next week. The site remains a very dangerous area and people should not enter it for any reason. The Environmental Protection Agency has increased security in the interests of public safety and to prevent further trespass in the area.
And …
2. EPA to Develop Remediation Plan for Kerdiffstown Landfill, Naas, County Kildare.
Date released: Feb 18 2011, 3:26 PM
The EPA, HSE, Kildare County Council, Defence Forces and Gardaí have, for the past 27 days, been co-ordinating actions to deal with the fire and other environmental issues at Kerdiffstown Landfill, near Naas. In particular, the EPA has been working closely with Kildare Fire Service, providing expert advice in fighting the serious fire at the Kerdiffstown landfill site, contracting in providers of cold gas injection equipment and providing air monitoring and analysis. The EPA is exercising its powers under Section 56 of the Waste Management Act to secure the site and to start the longer-term process of remediation of the whole site. Already the EPA has begun the following preliminary works:
- removing stockpiles of fire-risk waste ;
- providing 24-hour security personnel at the site for the long-term ;
- establishing an on-site office ;
- increased on-site monitoring and inspection ;
- dealing with immediate Health & Safety issues on the site ;
- removing landfill leachate.
As the plan for the remediation progresses, the EPA will be meeting with the local community on a regular basis in order to hear their views and update them on the remediation project. Remediation works will be phased and the EPA will prioritise work that alleviates odour from the site in the short to medium term. Funding for the short-term emergency works to date has been provided by the Department of Environment, Heritage & Local Government. Further funding for the remediation will be released on a phased basis. The EPA has taken enforcement action against those involved in the operation of the Kerdiffstown site, including three High Court cases. High Court orders are in place preventing the deposit of any further waste onto the Kerdiffstown site. The EPA will use its powers under the Waste Management Acts to seek recovery of all costs expended by the State during the remediation project. The EPA is also seeking orders against directors of the companies who formerly operated the site in order to recover these costs. A criminal investigation file relating to the previous operations at the site has been submitted to the Director of Public Prosecutions.
A lot of words have been used in these press releases … but the amount of actual information which has been communicated to the public is Sweet FA ! And … please note well … there is no statement that the Landfill Fire has been extinguished.
.
PROTECTION OF FIREFIGHTERS & KERDIFFSTOWN LOCAL COMMUNITY
We consider that it is very important for Firefighters and Members of the Kerdiffstown Local Community, i.e. anybody who lives within 2 Km of the Landfill Site, to have sufficient information about Landfill Fires … in order to ask some pertinent questions about this fire incident.
I hate to say this … but, languishing on an important page of the FireOx International WebSite for many years … http://www.sustainable-design.ie/fire/proenv.htm … unloved (?!?) … has been this 2002 United States Report …
U.S. Fire Administration – Federal Emergency Management Agency
May 2002 / FA-225
LANDFILL FIRES – Their Magnitude, Characteristics, and Mitigation
Click the Link Above to read and/or download PDF File (583 kb)
.
As you read the document … pinch yourself hard, and try to remember that the Regulatory Control over Landfill Sites in Ireland has been LITE-LITE-LITE !!! … That there has been much illegal dumping all over the country !! … AND … That some Local Authorities have even forgotten where old, inactive Landfill Sites are located … a case I myself encountered in Clontarf, within the functional area of what was then known as Dublin Corporation !
Black and white drawing ... Figure 1 in the 2002 U.S. FEMA Landfill Fires Report above ... showing the components of a Regulated Landfill Site, courtesy of the California Waste Management Board. How many Landfill Sites in Ireland, or in Europe for that matter, have all ... or any ... of the components illustrated above ? Click to enlarge.
.
LANDFILL EMISSIONS – CLIMATE CHANGE & FIRE SAFETY ISSUES !
Extract from the 2002 U.S. Report … Page 8 …
Landfill emissions are the result of the decomposition of organic materials in the landfill (including yard waste, household waste, food waste, and paper). Because of the nature of the construction of landfills, this decomposition is anaerobic and results in the production of large quantities of Methane (which is highly flammable) and Carbon Dioxide. In fact, landfills are the largest source of methane emissions in the United States, accounting for 35% of methane emissions in 1999. MSW (municipal solid waste) landfills generate about 93% of U.S. landfill emissions; industrial landfills account for the remaining emissions. Methane emissions from landfills are affected by site-specific factors such as waste composition, available moisture, and landfill size. Approximately 28% of the methane generated in landfills in 1999 was recovered. The remainder of landfill-generated methane was dispersed in the air.
Approximately 50% of gas emitted from landfills is methane; carbon dioxide accounts for about 45 percent, and the remainder is composed of nitrogen, oxygen, hydrogen, and other gases. Both Methane and Carbon Dioxide are Greenhouse Gases (GHG’s) that pose environmental problems. Of the two gases, methane is far more potent than carbon dioxide.
[Media reports have also stated that Carbon Dioxide was used during attempts to suppress the Kerdiffstown Landfill Fire in County Kildare !?!]
.
HEALTH EFFECTS OF LANDFILL FIRES !
Extract from the 2002 U.S. Report … Pages 14 & 15 …
In addition to the burn and explosion hazards posed by landfill fires, smoke and other by-products of landfill fires also present a health risk to firefighters and others exposed to them. Smoke from landfill fires generally contains Particulate Matter (the products of incomplete combustion of the fuel source), which can aggravate pre-existing pulmonary conditions or cause respiratory distress. As with all fires, those in landfills produce toxic smoke and gases. The danger and level of toxicity of these gases depend on the length of exposure one has to them and on the type of material that is burning.
Underground fires can result in CO (Carbon Monoxide) levels in excess of 50,000 ppm (parts per million) – the Occupational Safety & Health Administration (OSHA) permissible exposure limit for CO is 50 ppm. OSHA standards prohibit worker exposure to more than 50 parts of the gas per million parts of air averaged during an 8-hour time period. Carbon Monoxide is harmful when breathed because it displaces oxygen in the blood and deprives the heart, brain, and other vital organs of oxygen, which can cause permanent damage or death.
Another serious concern in landfill fires is the emission of Dioxins. Accidental fires at landfills and the uncontrolled burning of residential waste are considered the largest sources of dioxin emissions in the United States. The term ‘dioxins’ refers to a group of chemical compounds with similar chemical and biological characteristics that are released into the air during the combustion process. Dioxins are also naturally occurring and are present throughout the environment. However, exposure to high levels of dioxins has been linked to cancer, liver damage, skin rashes, and reproductive and developmental disorders.
.
ENVIRONMENTAL IMPACT OF LANDFILL FIRES !
Extract from the 2002 U.S. Report … Pages 16 & 17 …
The smoke and run-off from landfill fires can be dangerous to those living in the area and to the environment. It is important that air and water quality issues be addressed early in a fire suppression operation to prevent contamination as much as possible. As mentioned earlier, water used to suppress a landfill fire can overwhelm a facility’s leachate collection system, if one exists (older facilities may have been constructed prior to regulations requiring leachate collection systems).
.
FIRE & LANDFILL CONTENTS !
Extract from the 2002 U.S. Report … Page 17 …
Fires occurring in landfills where hazardous wastes are buried can be particularly difficult. In past years, illegal dumping of hazardous and toxic materials in landfills and other dumping sites was relatively common. When a fire occurs and rescue workers have wrong or misleading information about the buried contents (e.g., illegal or unknown toxic or radioactive wastes), the fire suppression operation can be extremely dangerous.
Although not a landfill fire, the Wade Dump Fire in February 1978 clearly illustrates the dangers posed by fires involving unknown hazardous materials. Firefighters responded to a suspected tyre fire at an abandoned rubber shredding plant on the Delaware River outside of Philadelphia. They were unaware that the property’s owner and namesake, Melvin Wade, had transformed the plant into one of the most toxic hazardous waste dumpsites in U.S. history. By the night of the fire, more than 3 million gallons of cyanide, benzene, toluene, and other chemicals were stored on the site – plus thousands of junk tyres. The burning chemicals produced multi-coloured smoke and noxious fumes, which alerted firefighters to the unusual nature of the fire they were fighting. Intensified by chemicals and other fuels, the fire raged for hours. Drums of chemicals exploded, injuring firefighters and even damaging fire trucks. As the night progressed, firefighters and other emergency workers noticed that the chemicals were dissolving their protective gear and making it difficult for them to breathe; more than 40 firefighters were sent to a nearby hospital for treatment. Over the past 20 or more years, dozens of those who were present at the Wade Dump fire have become ill, and many have died from cancers and other diseases. Melvin Wade and others responsible for creating the toxic site were found criminally responsible for their actions.
.
JOINING SOME DOTS – CONTAMINATED PUBLIC WATER SUPPLIES IN IRELAND
On Thursday, 17 February 2011 … the Environmental Protection Agency (EPA) released the following report … with an accompanying, ‘spinned’ press release …
Environmental Protection Agency – Ireland
2011-02-17
The Provision & Quality of Drinking Water in Ireland – A Report for the Years 2008-2009
Click the Link Above to read and/or download PDF File (2.77 Mb)
.
Once again … pinch yourself hard, and try to remember that the Regulatory Control over Public Water Supplies in Ireland has been LITE-LITE-LITE !!! Our Public Water Supplies are not in good shape … to say the least. However, the management and control of the country’s landfill sites – legal, illegal and no longer known – IS a relevant and related issue to the contamination of our public water supplies … not the only issue.
Now, I don’t know about you … but I certainly am not happy about either the accuracy, or the reliability, of the recent EPA Report on Ireland’s Public Water Supplies !
.
.
END
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 http://www.environ.ie/ … 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 … http://www.ifa.ie/CrossSectors/ClimateChangeandRenewables.aspx … while the Irish Business & Employers Confederation (IBEC) have been predictably negative and a right pain in the ass … see this Page on their WebSite … http://www.ibec.ie/IBEC/Press/PressPublicationsDocLib3.nsf/vPages/2BEBCAA836D7D6E08025781D00428C39?OpenDocument
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.
.
MEANWHILE …
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 !!
.
IRELAND’S NEARLY-ACTUAL CLIMATE CHANGE PERFORMANCE
On 14 December 2010, the Economic & Social Research Institute (ESRI) published a report: ‘The Energy & Environment Review 2010′ … available for download at http://www.esri.ie/ … 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.
.
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 … ?
.
SOME SPECIFIC COMMENTS ON THE 2010 CLIMATE CHANGE RESPONSE BILL
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 …
TO MAKE PROVISION FOR THE SETTING, AND ACHIEVEMENT, OF NATIONAL GREENHOUSE GAS EMISSION REDUCTION TARGETS TO FURTHER TRANSITION TO A SUSTAINABLE, CLIMATE CHANGE RESILIENT AND LOW CARBON-BASED FUEL CONSUMING SOCIETY ;
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.
.
.
END
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.
.
.
END
European Union Economic Governance – Too Late For Dithering !
2010-12-22: November & December 2010 … when the shit really started to hit the international economic fan ! … there has been an excess of hysterical nonsense in the Irish Media concerning growing European Union (EU) Economic Governance … and a perceived erosion of Irish National Sovereignty. How sad ?!?
Note: Economic Environment … the intricate web of real and virtual human commercial activity – operating at micro and macro-economic levels – which facilitates, supports, but sometimes hampers or disrupts, human interaction in the Social Environment.
Note: Social Environment … the complex network of real and virtual human interaction – at a communal or larger group level – which operates for reasons of tradition, culture, business, pleasure, information exchange, institutional organization, legal procedure, governance, human betterment, social progress and spiritual enlightenment, etc.
However, let me sketch out an altogether different and much more positive picture !
.
Thesis – My Argument
[During 2009, I first raised this issue in meetings of the IIEA (Institute of International & European Affairs) Economists' Group, in Dublin.]
Towards the end of 2010 … we can now see that Inter-Governmental Economic Governance in the European Union has failed … miserably. This has not only destabilized the EuroZone … but the entire European Union, itself, as a political entity … and will continue to do so … until Economic Governance is brought much closer to, and fully within, the Community Method … which is a lengthy and complex process.
Back in 2009, however, when the Financial Markets were not in such a mad frenzy … it would have been natural to imagine that an interim stage in this process would most probably be to adopt an Open Method of Co-Ordination. This is no longer an option … being too little, too late, to calm the Markets.
Throughout this process of reform, the European Central Bank (ECB) and the National Central Banks can, and must, retain their independence … as legally mandated in European Union Primary Legislation, i.e. the Treaties.
.
Three Concerns I have had for some time …
- Economists don’t know the Community Method from the Rhythm Method, and they are ill-equipped to deal with matters of Mainstream European Union Institutional Reform ;
- The use of Economic Performance Indicators in the EU Stability & Growth Pact is simplistic and crude … and, therefore, very problematic ;
- Economic Performance Indicators must be improved … qualitatively … and be mainstreamed in considerations, and the implementation, of Sustainable Human & Social Development … as legally mandated in the EU Treaties.
.
Mr. Olli Rehn, European Commissioner for Economic & Monetary Affairs recently delivered a speech at the Institute of International & European Affairs, in Dublin …
Mr. Olli Rehn, European Commissioner
9 November 2010
Reinforcing EU Economic Governance: Relevance for Ireland
Click the Link Above to read and/or download PDF File (39kb)
However … instead of trying to desperately backfill the holes and gaps in the current, failed Inter-Governmental Method of Economic Governance in the European Union … Commissioner Rehn should be clearly identifying the proper target as the Community Method of Economic Governance … and plotting an appropriate course to reach that target … as soon as practicable !
.
This is a useful background document … and includes a lot of information about the EU Stability & Growth Pact …
European Commission & General Secretariat of the EU Council
June 2007
EU Economic & Monetary Union – Legal & Political Texts
Click the Link Above to read and/or download PDF File (2.66 Mb)
Since Ireland joined the European Economic Community (EEC) in 1973 … after 10 years of accession negotiations ! … an ‘informed’ view of European Integration has always been that the different Countries are pooling their national sovereignty, in an expanding range of specific areas, for the greater benefit of all their citizens. This has certainly been the experience of Ireland. And … let us also not forget that Irish Politicians and Senior Civil Servants have participated directly – at all stages – in the development of the EMU Legal & Political Texts listed. There is no such thing as a Domineering ‘Brussels’ Big Brother !
.
This is the most recent update of the EuroZone’s Economic Performance Indicators …
European Commission, Directorate-General for Economic & Financial Affairs (DG ECFIN)
2 December 2010
Key Economic Indicators for the Euro Area
Click the Link Above to read and/or download PDF File (360kb)
It is now widely acknowledged that Gross Domestic Product (GDP) is neither a reliable nor an adequate indicator of Sustainable Human & Social Development. But … that is another story … for another day !
.
Community & Inter-Governmental Methods of Governance
The Community Method is the expression used for the most common and effective operating and decision-making mode of institutions in the European Union. It proceeds from an integration logic, with due respect for the subsidiarity principle … and has the following salient features:
- European Commission monopoly of the Right of Initiative, with a strong monitoring role in implementation ;
- should consensus not be achieved, widespread use of Qualified Majority Voting in the Council of the European Union ;
- an active, participatory role for the European Parliament ;
- uniform interpretation of EU Law by the Court of Justice.
In contrast to the … Inter-Governmental Method … which proceeds from an inter-governmental logic of co-operation between EU Member States … to a large extent outside the institutional framework of the European Union … and has the following salient features:
- the European Commission’s Right of Initiative is shared with the Member States or confined to specific areas of activity … with little, if any, monitoring role for the Commission in implementation ;
- the Council of the European Union generally acts unanimously … and unilaterally ;
- the European Parliament has merely a consultative role ;
- the Court of Justice plays only a minor role.
.
Open Method of Co-Ordination
The Open Method of Co-Ordination (OMC) developed as an instrument of the 2000 Lisbon Strategy, and provided a new framework for co-operation between the EU Member States, whose national policies could thus be directed towards certain common objectives.
Under this method of governance, the Member States are evaluated by one another (peer pressure), with the European Commission’s role being limited to ‘lite’ surveillance. The European Parliament and the Court of Justice play virtually no part in the OMC process.
The Open Method of Co-Ordination takes place in policy areas which fall within the competence of the Member States … such as employment, social protection, social inclusion, education, youth and training.
It is based principally on:
- jointly identifying and defining objectives to be achieved (adopted by the Council of the European Union) ;
- jointly established measuring instruments (statistics, indicators, guidelines) ;
- benchmarking, i.e. comparison of the Member States’ performance and exchange of best practices (oversight by the European Commission).
Depending on the areas concerned, the OMC involves so-called ‘Soft Law’ Measures which are binding on the Member States to varying degrees but which never take the form of ’Hard Law’ Directives, Regulations or Decisions. Thus, in the context of the Lisbon Strategy, the OMC required the Member States to draw up national reform plans and to submit them to the European Commission.
.
Colour photograph showing the last resting place, in Arbour Hill Cemetery Dublin, for many - not all - Executed Leaders of the 1916 Revolution. The Memorial was designed by G. McNicholl. Photograph taken by CJ Walsh. 2010-10-24. Click to enlarge.
Ireland’s National Sovereignty in 2010/2011 ?
On a beautiful sunny day, this past autumn … I again visited Arbour Hill Cemetery in Dublin … the last resting place for many Executed Leaders of the 1916 Revolution … an event which finally initiated an irrevocable process of terminating a prolonged period of barbaric external imperial domination and cultural cleansing of the indigenous population …
Colour photograph showing, in the background, a latin cross and the Irish language version of the 1916 Proclamation of Independence inscribed on the stone wall, with the simple grass-covered graves of Executed Leaders in the foreground. Detail of the 1916 Revolution Memorial in Arbour Hill Cemetery, Dublin. Photograph taken by CJ Walsh. 2010-10-24. Click to enlarge.
.
On the wall behind the graves … the 1916 Proclamation of Independence is inscribed in the Irish Language, and also in English …
Poblacht na hEíreann
THE PROVISIONAL GOVERNMENT OF THE IRISH REPUBLIC
TO THE PEOPLE OF IRELAND
IRISHMEN AND IRISHWOMEN: In the name of God and of the dead generations from which she receives her old tradition of nationhood, Ireland, through us, summons her children to her flag and strikes for her freedom.
Having organized and trained her manhood through her secret revolutionary organization, the Irish Republican Brotherhood, and through her open military organizations, the Irish Volunteers and the Irish Citizen Army, having patiently perfected her discipline, having resolutely waited for the right moment to reveal itself, she now seizes that moment, and, supported by her exiled children in America and by gallant allies in Europe, but relying in the first on her own strength, she strikes in full confidence of victory.
We declare the right of the people of Ireland to the ownership of Ireland, and to the unfettered control of Irish destinies, to be sovereign and indefeasible. The long usurpation of that right by a foreign people and government has not extinguished the right, nor can it ever be extinguished except by the destruction of the Irish people. In every generation the Irish people have asserted their right to national freedom and sovereignty: six times during the past three hundred years they have asserted it in arms. Standing on that fundamental right and again asserting it in arms in the face of the world, we hereby proclaim the Irish Republic as a Sovereign Independent State, and we pledge our lives and the lives of our comrades-in-arms to the cause of its freedom, of its welfare, and of its exaltation among the nations.
The Irish Republic is entitled to, and hereby claims, the allegiance of every Irishman and Irishwoman. The Republic guarantees religious and civil liberty, equal rights and equal opportunities to all its citizens, and declares its resolve to pursue the happiness and prosperity of the whole nation and of all its parts, cherishing all the children of the nation equally, and oblivious of the differences carefully fostered by an alien government, which have divided a minority from the majority in the past.
Until our arms have brought the opportune moment for the establishment of a permanent National Government, representative of the whole people of Ireland and elected by the suffrages of all her men and women, the Provisional Government, hereby constituted, will administer the civil and military affairs of the Republic in trust for the people.
We place the cause of the Irish Republic under the protection of the Most High God, Whose blessing we invoke upon our arms, and we pray that no one who serves that cause will dishonour it by cowardice, inhumanity, or rapine. In this supreme hour the Irish nation must, by its valour and discipline and by the readiness of its children to sacrifice themselves for the common good, prove itself worthy of the august destiny to which it is called.
Signed on Behalf of the Provisional Government,
THOMAS J. CLARKE,
SEAN Mac DIARMADA, THOMAS Mac DONAGH,
P. H. PEARSE, EAMONN CEANNT,
JAMES CONNOLLY, JOSEPH PLUNKETT.
.
As We Approach the 100th Anniversary of the 1916 Revolution … Ireland has failed to implement and foster the social values so eloquently elaborated in the 1916 Proclamation of Independence … widespread, deeply ingrained corruption infects our economic environment … and the institutions of national governance are dysfunctional and no longer ‘fit for purpose’ … while individuals within those institutions rise in rank according to their own natural level of incompetence.
Politically … Ireland has not yet properly matured as an Independent State.
.
Ireland’s Relationship with the European Union … I am more than a little curious as to why Ireland is not associated with Declaration No.52, which is annexed to the Treaty of Lisbon …
52. Declaration by the Kingdom of Belgium, the Republic of Bulgaria, the Federal Republic of Germany, the Hellenic Republic, the Kingdom of Spain, the Italian Republic, the Republic of Cyprus, the Republic of Lithuania, the Grand-Duchy of Luxembourg, the Republic of Hungary, the Republic of Malta, the Republic of Austria, the Portuguese Republic, Romania, the Republic of Slovenia and the Slovak Republic on the symbols of the European Union
Belgium, Bulgaria, Germany, Greece, Spain, Italy, Cyprus, Lithuania, Luxemburg, Hungary, Malta, Austria, Portugal, Romania, Slovenia and the Slovak Republic declare that the flag with a circle of twelve golden stars on a blue background, the anthem based on the ‘Ode to Joy’ from the Ninth Symphony by Ludwig van Beethoven, the motto ‘United in diversity’, the euro as the currency of the European Union and Europe Day on 9 May will for them continue as symbols to express the sense of community of the people in the European Union and their allegiance to it.
.
Yes … we have a lot to discuss before 2016 !
.
.
END
‘Antilia’, The New Mumbai High-Rise Building – What A Mother !
It is difficult for any foreign news item, no matter how important, to penetrate the current economic media haze in Ireland and Europe … but latest reports from India put the casualty list after the Five-Storey Residential Building Collapse at Lalita Park in East Dilli’s Laxmi Nagar Area … which occurred on Monday evening (local time), 15 November 2010 … at 69 people dead, 82 injured, with perhaps as many as another 20 people still missing.
The Occupants of 38 Similar Neighbouring Properties have been told to immediately vacate the buildings by Dilli’s Municipal Authority.
Colour photograph showing the scene of the Five-Storey Residential Building Collapse at Lalita Park in East Dilli's Laxmi Nagar Area, which occurred on Monday evening (local time), 15 November 2010. Click to enlarge.
.
Faulty Construction appears to have been the principal cause for this serious collapse, according to media reports. It may also have been an extra storey illegally added to an original, weak building structure … and/or heavy water logging of the building’s basement from the nearby Yamuna River during recent storms.
Dilli … its local name … is a very old and large city, and is the Capital of India. New Delhi refers to the relatively more recent British Imperial Quarter … the urban plan of which and its principal buildings were designed by the British Architect, Edwin Landseer Lutyens (1869-1944).
.
Within India, today, there is a strong political desire to achieve ‘Developed Country’ Status by 2020. However, in Developed Countries … Collapse Level Events (CLE’s) are completely unacceptable … witness the public reaction to the collapses on 9-11 in New York.
The 2005 National Building Code of India … a copy of which is close at hand in my Dublin Office … is not mandatory. It closely resembles the informal (i.e. not legal), but prescriptive, ‘Draft’, ‘Revised Draft’ and ‘Proposed’ Irish Building Regulations dating from the 1970′s and 1980′s … another Irish solution to an Irish problem ! The 2005 Indian Code has been drafted to deal with a large range of simple building types, their construction and related issues … certainly not any sort of Iconic, High-Rise Building of Innovative Design. Anyway, the Code is still only at the initial stages of being adopted in India’s different States. AND … there is not yet in place a National System of Local Building or Independent Technical Control … never mind an ‘Effective’ System of Control !
In a lightly regulated European legislative environment … it may come as a surprise to find out that the level of non-compliance on building sites in France, for example, has been placed as high as 68%, according to a colleague from CSTB (Centre Scientifique et Technique du Bâtiment) … the rate of non-compliance which was found by Energy Ireland (SEAI) on Irish building sites was 70%.
In India’s unregulated legislative environment … higher levels of non-compliance should be expected amongst indigenous building organizations. AND … the percentage rate of non-compliance with foreign building organizations should be assumed to at least match those European figures quoted above.
There is a further complication in India and most of the rest of the developing world, however, because U.S. building design consultants will typically use one of the United States of America’s National Model Building Codes (including the International Building Code, which is also a U.S. National Model Building Code) … in preference to local building codes … whatever the local codes do, or do not, say. We have a long experience of this approach in Ireland ! BUT … the U.S. Model Building Codes are not being adapted to suit local site conditions, building practices, safety factors, etc. It sounds messy … and it is very messy !!
.
A few quick words about INDIA (Bhārata or Bharat, in Sanskrit) … a federal republic and a burgeoning country of extreme contrasts … which has a population of some 1,173,108,018 People (July 2010 estimated, U.S. CIA’s World Factbook).
Rapid economic development has driven India to prominence on the world stage … despite pressing problems such as significant overpopulation, extensive poverty and a startling degree of social inequity, environmental degradation, such as deforestation, soil erosion, overgrazing, desertification, air pollution from industrial effluents and vehicle emissions, water pollution from raw sewage and run-off of agricultural pesticides … and the widespread corruption which is a natural consequence following an extended period of harsh external imperial domination. India became an independent country in 1947.
For the last few years, I have been travelling to this beautiful, complex land … from Chennai (Madras) and Bengaluru (Bangalore) in the south … to Dilli in the north. Over 70 years before … my father, a native of Midleton in County Cork, was a teacher in Kolkata (Calcutta) and further north than Dilli. He was trapped, there, from coming home during the 2nd World War (1939-1945).
For me, it has been a warm and rewarding experience to meet the people of India.
And … I am also very grateful for the hospitality shown by FSAI (Fire & Security Association of India). Working together, we have successfully set a future direction for the FSAI’s National Fire Safety Agenda in India.
.
Less recently in the news and, it seems, always for the wrong reasons … Mumbai (Bombay) … where of the approximately 14 Million (1.4 Crore, an Indian Unit of Measure) People living in this western city … capital of the State of Maharashtra, and the financial and entertainment capital of the country … an estimated 7,500,000 (75 Lakhs, an Indian Unit of Measure) People survive in its Slums.
Mumbai is also located in a Seismically Active Zone, due to the presence of 23 fault lines in the region …
Colour image showing the Seismic Zones on a Map of India. Taken from Indian Standard IS 1893 (Part 1) : 2002. Click to enlarge.
.
During past years, a pattern of extraordinarily violent ‘Hive-Attacks’ have been carried out in Mumbai, with the aim of causing widespread terror amongst the general population and disrupting the city’s important Social & Economic Environments. The attacks have involved the strategic targeting of Built Environment Places of Public Resort, Iconic Buildings, High-Rise Buildings, Buildings having a Critical Function, Transport Infrastructure and Service Utilities:
- On 12 March 1993 … a series of 13 co-ordinated bombings … up until that date, the most destructive bomb explosions in Indian history … beginning at the Stock Exchange Building … resulted in 257 deaths and over 700 injuries.
- On 11 July 2006 … 209 people were killed and over 700 injured when seven bombs exploded on the city’s commuter trains.
- Commencing on 26 November 2008, and lasting for three days … a series of ten co-ordinated attacks resulted in 175 deaths, 308 injuries, and severe damage to a number of luxury hotels and historical landmarks.
.
Colour photograph showing 'Antilia' - the recently occupied Private, Iconic, High-Rise Mansion of Innovative Design belonging to Shri Mukesh Ambani in Mumbai. Click to enlarge.
How strange it is, then, in this particular city … that at the end of October 2010 … after seven years of construction … an Indian businessman, Shri Mukesh Ambani, and his family … should choose to occupy their own 27 floor/173 metre tall Private Mansion … an Iconic, High-Rise Building of Innovative Design … within the near-sight of millions of slum dwellers ! The building is called ‘Antilia’ … the name of a mythical island in the Atlantic Ocean, lying to the west of Portugal ?!?
OK … Let’s Get the Easy Bits Over First …
1. Architecturally … and somebody, somewhere needs to say this … ‘Antilia’ is a mother of an ugly building. There is an old joke about a committee starting out to design a horse, and ending up with a camel. In this case, a group of people started to design an impressive building, and ended up with a spotty rhinoceros !
2. From the point of view of Sustainable Human & Social Development … consider the resources used in the design, construction and operation of this mother … an architectural phallic symbol of obscene opulence and cheap looking ’bling-bling’ … in close proximity to extensive and deep-rooted slum poverty. It may be ‘Green’(?) … BUT … this building is certainly Anti-Sustainable ! Is it any wonder that a Class Action has recently been taken against the U.S. Green Building Council and its LEED (Leadership in Energy and Environmental Design) Building Rating System in the U.S. Courts ?
The Difficult Issues …
3. Structural Resilience … I would really like to be assured, by a person competent to do so, that ‘Antilia’ has actually been designed to withstand “a magnitude-8 earthquake” (according to local media reports), i.e. no significant damage will occur to the structure or fabric of the building.
AND … that ‘Antilia’ has been designed to properly resist disproportionate damage in the event that any “military grade explosions” (according to local media reports) happen in the building, i.e. no significant damage will occur to the building’s structure.
But … why only “military grade explosions” ? If an ‘incident’ does take place in the building, it will not be the poorly equipped Indian Army who will be placing the ‘ordinary’ explosives … and the Army will not have the required expertise to place the explosives in the most vulnerable part of the structure.
Never assume that the people who plan these sorts of ‘incidents’ are anything other than highly motivated, intelligent and technically competent !
4. Fire Protection & Safety … this requires much repetition … but the 2005 National Building Code of India cannot deal adequately with this type of building … an Iconic, High-Rise Building of Innovative Design. AND, most obviously … the 2005 Indian Code does not incorporate any of the important Recommendations contained in the 2005 & 2008 NIST(USA) Reports on the 9-11 WTC Buildings 1,2 & 7 Collapses. I have suggested that this be done, with urgency, during an upcoming revision to the Code … but there is resistance !
9-11 in New York exposed a catastrophic failure … at all levels … in all of OUR common practices and procedures (architectural, engineering, first emergency response, regulatory, legislative, etc., etc) … used to design, construct and operate buildings generally !
.
So … what does ‘Antilia’ … say about the Man … the Institutions of Governance and State Administration within Maharashtra … and India generally … at this time ???
Has this Man been well served by His Advisors … technical and otherwise ????
.
.
END
Search
Recent Comments
- therese on Accessible Toilet Room in a Japanese Public Place – Kanazawa
- noel on Fixing ‘Priory Hall’ in Dublin – Practical Solutions Needed Now !
- dt on Beautiful Sunset – Turgutreis, Bodrum Peninsula, Turkey
- Cathy on A More Balanced Presentation of Recent UN Gaza Flotilla Report
- Jolyn on New EU Construction Product Regulation 305/2011 – Halleluiah !
Categories
- architecture
- art
- built environment
- cinema
- climate change
- design
- economic environment
- eu law
- european union
- fire
- human & social rights
- human environment
- human health & safety
- institutional environment
- international law
- judicial
- media
- national law
- natural environment
- photography
- political environment
- regulations & standards
- social environment
- sustainability
- technical control
- travel
- virtual environment
| S | M | T | W | T | F | S |
|---|---|---|---|---|---|---|
| « Jan | ||||||
| 1 | 2 | 3 | 4 | |||
| 5 | 6 | 7 | 8 | 9 | 10 | 11 |
| 12 | 13 | 14 | 15 | 16 | 17 | 18 |
| 19 | 20 | 21 | 22 | 23 | 24 | 25 |
| 26 | 27 | 28 | 29 | |||
Links
- 'Spirit of Ireland' Project – National Energy Independence. At last … some 'real' Innovation in this country !
- 2bscene Web Design & Development – Dublin, Ireland.
- AL JAZEERA – News & Views from the ARAB WORLD (1431 H)
- ALBA – Alianza Bolivariana para los Pueblos de Nuestra América / Bolivarian Alliance for the Peoples of Our America
- Amnesty International – Irish Section
- CJ Walsh: Architectural, Design & Technical Control Practice (Ireland, Italy & Turkey)
- Contact Us – Sustainable Design International Ltd. (Ireland, Italy & Turkey)
- Cuba Support Group – Ireland
- Department of the Environment, Heritage & Local Government (DEHLG) – Ireland
- E-PRTR – European Pollutant Release and Transfer Register … a Europe-wide register providing easily accessible key environmental data from industrial facilities in EU Member States and in Iceland, Liechtenstein & Norway.
- EL NACIONAL – News & Views from VENEZUELA
- EU Fundamental Rights Agency – The Agency focuses on the situation of fundamental rights in the European Union (EU) and its 27 Member States.
- EUR-Lex – Full, direct and free access to all European Union (EU) Legislation
- European Consumer Centres' Network (ECC-Net) – European Union (EU) wide network of Consumer Protection Centres, co-sponsored by the European Commission and the Member States. The network comprises 29 Centres … one in each of the 27 EU Member States
- EUROPEANA – Access to Europe’s Cultural & Scientific Heritage though a Cross-Domain Digital Portal
- FireOx International: Fire Engineering Consultancy, Research & Design Practice (Ireland, Italy & Turkey)
- GRANMA INTERNACIONAL – News & Views from CUBA
- HÜRRİYET – News & Views from TURKEY
- Ireland – Information about our Public Institutions, including Pretty Pictures of our green countryside !
- Irish Seed Savers Association … Working to Conserve Irish Biodiversity. They research, locate, preserve & use traditional varieties, cultivars of fruit, vegetables, potatoes & grains.
- James Taylor – Singer & Songwriter
- JOURNAL DE BRASÍLIA – News & Views from BRAZIL
- Kanchi (Ireland) – Changing Society's View of Disability for the Better
- NAVBHARAT TIMES – News & Views (in Hindi) from INDIA
- PRAVDA – News & Views from RUSSIA
- Robert F Kennedy Centre for Justice & Human Rights (USA)
- Rocky Mountain Institute (USA) – Super Energy Efficiency by Design
- RTE Lyric FM – Classical (in its widest meaning !) Music on Irish Radio
- Senator Shane Ross – Ireland's Principal Economics Troubleshooter. What happened to George ?
- Survivors of Institutional Abuse Ireland [SOIAI] – WE (collectively) did not cherish all the children of OUR nation equally !
- Sustainable Design International: Experts in the Theory & Implementation of Sustainable Human & Social Development (Ireland, Italy & Turkey)
- Tom Doyle's Blog :: TALK
- UNFCCC (United Nations Framework Convention on Climate Change) + Kyoto Protocol + COP-15
- United Nations Human Rights Council – Established 15 March 2006
- WikiLeaks – A non-profit media organization dedicated to bringing important news and information to the public.
- WISE – Water Information System for Europe … a single location (portal) where geographically-mapped information on water-related issues can be found for the whole of Europe.
- XINHUA News Agency – News & Views from CHINA
Archives
- January 2012
- December 2011
- November 2011
- October 2011
- September 2011
- July 2011
- May 2011
- April 2011
- March 2011
- February 2011
- January 2011
- December 2010
- November 2010
- October 2010
- June 2010
- May 2010
- April 2010
- March 2010
- February 2010
- January 2010
- December 2009
- November 2009
- October 2009
- September 2009
- July 2009
- June 2009
- May 2009
- April 2009
- March 2009
- February 2009
- January 2009
- December 2008