‘A Gentle Whisper in Your Ear’

NIST’s Recommendations on the 9-11 WTC Building Collapses

2011-10-25:  Since shortly after my visit to Lower Manhattan in mid-October 2001 … we have maintained an Archive Page on ‘Structural Fire Engineering, World Trade Center Incident (9-11) & Fire Serviceability Limit States‘ … at SDI’s Corporate WebSite.  And I have referenced here … many, many times … the Recommendations contained in the 2005 & 2008 Final Reports of the U.S. National Institute of Standards & Technology (NIST) on the 9-11 World Trade Center Building 1, 2 & 7 Collapses.

In this post (and a series of future posts) … I find it most necessary that the 2005 & 2008 NIST Recommendations now be presented for everyone to read.  Yes, some of Recommendations apply specifically to Tall and Very Tall Buildings … and Building Designers in India, China, Brazil, Russia & South Africa (BRICS), the Arab Gulf Region, Europe and North America, etc., should be fully aware of their contents.

BUT … I am also strongly convinced … precisely because I am an Architect, a Fire Engineer and a Technical Controller … that most of the NIST Recommendations apply to ALL Buildings … so catastrophic was the failure exposed on that fateful day (11 September 2001) … in all of our common design and construction practices … and our operation, maintenance and emergency response procedures !

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PRELIMINARY COMMENTS

  1.     Extract from Paragraph #9.2, Chapter 9, NIST Final Report on the Collapse of the World Trade Center Towers – Report Reference NIST NCSTAR 1 (2005) …

• NIST believes  that these Recommendations are both realistic and achievable within a reasonable period of time, and that their implementation would make buildings safer for occupants and emergency responders in future emergencies.
• NIST strongly urges  that immediate and serious consideration be given to these Recommendations by the building and fire safety communities – especially designers, owners, developers, codes and standards development organizations, regulators, fire safety professionals, and emergency responders.
• NIST also strongly urges  building owners and public officials to:  (i) evaluate the safety implications of these Recommendations for their existing inventory of buildings;  and (ii) take the steps necessary to mitigate any unwarranted risks without waiting for changes to occur in codes, standards, and practices.

  2.     At the time of writing … it is important to point out that although they are related Structural Concepts … and there is still, to this day, a lot of confusion about these concepts in the USA … it is important to clearly distinguish between …

Disproportionate Damage

The failure of a building’s structural system  (i) remote from the scene of an isolated overloading action;  and (ii) to an extent which is not in reasonable proportion to that action.

Fire-Induced Progressive Collapse

The sequential growth and intensification of distortion, displacement and failure of elements of construction in a building – during a fire and the ‘cooling phase’ afterwards – which, if unchecked, will result in disproportionate damage, and may lead to total building collapse.

  3.     Recommendation 2, below, would certainly need to be understood and implemented within today’s additional design constraints of Sustainable Climate Change Adaptation and Resilience to Severe Weather Events.  Therefore … Design Wind Speeds must be increased, accordingly, for ALL Buildings.

  4.     As such a high level of performance is expected … indeed demanded … of a Sustainable Building … Sustainable Fire Engineering must be ‘reliability-based’.  In other words, it must have a rational, empirical and scientifically robust basis … unlike conventional fire engineering, which is yet aimlessly wandering around in pre-historic caves !

  5.     Finally … there is no use trying to hide the fact that progress on implementing the NIST Recommendations, within the USA, has been lamentably slow.  Outside that jurisdiction, the response has ranged from mild interest, to complete apathy, and even to vehement antipathy.  The implications arising from implementation are much too hard to digest … for long established fire safety professionals and researchers who are unswervingly committed to the flawed and out-of-date practices and procedures of conventional fire engineering and, especially, for vested interests !

However … is it either in society’s interest, or in the interests of our clients/client organizations … that, to give you a simple example which is relevant close to home, British Standard 9999 (published on 31 October 2008): ‘Code of Practice for Fire Safety in the Design, Management and Use of Buildings’ takes absolutely no account of any of the NIST Recommendations ?   As far as the British Standards Institution is concerned … 9-11 never happened … which I think is an inexcusable and unforgivable technical oversight !

For this reason, the General Public in ALL of our societies and Clients/Client Organizations in ALL countries should also be fully aware of the contents of these Recommendations …

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2005 NIST WTC RECOMMENDATIONS

GROUP 1.   Increased Structural Integrity

The standards for estimating the load effects of potential hazards (e.g. progressive collapse, wind) and the design of structural systems to mitigate the effects of those hazards should be improved to enhance structural integrity.

NIST WTC Recommendation 1.

NIST recommends that:  (1) progressive collapse be prevented in buildings through the development and nationwide adoption of consensus standards and code provisions, along with the tools and guidelines needed for their use in practice;  and (2) a standard methodology be developed – supported by analytical design tools and practical design guidance – to reliably predict the potential for complex failures in structural systems subjected to multiple hazards.

a.   Progressive collapse* should be prevented in buildings.

[ * F-19  Progressive collapse (or disproportionate damage) occurs when an initial local failure spreads from structural element to structural element resulting in the collapse of an entire structure or a disproportionately large part of it.]

The primary structural systems should provide alternate paths for carrying loads in case certain components fail (e.g. transfer girders or columns).  This is especially important in buildings where structural components (e.g. columns, girders) support unusually large floor areas.*

[ * F-20  While the WTC towers eventually collapsed, they had the capacity to redistribute loads from impact and fire damaged structural components and sub-systems to undamaged components and sub-systems.  However, the core columns in the WTC towers lacked sufficient redundant (alternative) paths for carrying gravity loads.]

Progressive collapse is addressed only in a very limited way in practice and by codes and standards.  For example, the initiating event in design to prevent progressive collapse may be removal of one or two columns at the bottom of the structure.  Initiating events at multiple locations within the structure, or involving other key components and sub-systems, should be analyzed commensurate with the risks considered in the design.  The effectiveness of mitigation approaches involving new system and sub-system design concepts should be evaluated with conventional approaches based on indirect design (continuity, strength and ductility of connections), direct design (local hardening), and redundant (alternate) load paths.  The capability to prevent progressive collapse due to abnormal loads should include:  (i) comprehensive design rules and practice guides;  (ii) evaluation criteria, methodology, and tools for assessing the vulnerability of structures to progressive collapse;  (iii) performance-based criteria for abnormal loads and load combinations;  (iv) analytical tools to predict potential collapse mechanisms;  and (v) computer models and analysis procedures for use in routine design practice.  The federal government should co-ordinate the existing programmes that address this need:  those in the Department of Defence;  the General Services Administration;  the Defence Threat Reduction Agency;  and NIST.  Affected Standards:  ASCE-7, AISC Specifications, and ACI 318.  These standards and other relevant committees should draw on expertise from ASCE/SFPE 29 for issues concerning progressive collapse under fire conditions.  Model Building Codes:  The consensus standards should be adopted in model building codes (i.e. the International Building Code and NFPA 5000) by mandatory reference to, or incorporation of, the latest edition of the standard.  State and local jurisdictions should adopt and enforce the improved model building codes and national standards based on all 30 WTC Recommendations (2005).  The codes and standards may vary from the WTC Recommendations, but satisfy their intent.

b.   A robust, integrated predictive capability should be developed, validated, and maintained to routinely assess the vulnerability of whole structures to the effects of credible hazards.  This capability to evaluate the performance and reserve capacity of structures does not exist and is a significant cause for concern.  This capability would also assist in investigations of building failure – as demonstrated by the analyses of the WTC building collapses carried out in this Investigation.  The failure analysis capability should include all possible complex failure phenomena that may occur under multiple hazards (e.g. bomb blasts, fires, impacts, gas explosions, earthquakes, and hurricane winds), experimentally validated models, and robust tools for routine analysis to predict such failures and their consequences.  This capability should be developed via a co-ordinated effort involving federal, private sector, and academic research organizations in close partnership with practicing engineers.

NIST WTC Recommendation 2.

NIST recommends that nationally accepted performance standards be developed for:  (1) conducting wind tunnel testing of prototype structures based on sound technical methods that result in repeatable and reproducible results among testing laboratories;  and (2) estimating wind loads and their effects on tall buildings for use in design, based on wind tunnel testing data and directional wind speed data.  Wind loads specified in current prescriptive codes may not be appropriate for the design of very tall buildings since they do not account for building-specific aerodynamic effects.  Further, a review of wind load estimates for the WTC towers indicated differences by as much as 40 % from wind tunnel studies conducted in 2002 by two independent commercial laboratories.  Major sources of differences in estimation methods currently used in practice occur in the selection of design wind speeds and directionality, the nature of hurricane wind profiles, the estimation of ‘component’ wind effects by integrating wind tunnel data with wind speed and direction information, and the estimation of ‘resultant’ wind effects using load combination methods.  Wind loads were a major factor in the design of the WTC tower structures and were relevant to evaluating the baseline capacity of the structures to withstand abnormal events such as major fires or impact damage.  Yet, there is lack of consensus on how to evaluate and estimate winds and their load effects on buildings.

a.   Nationally accepted standards should be developed and implemented for conducting wind tunnel tests, estimating site-specific wind speed and directionality based on available data, and estimating wind loads associated with specific design probabilities from wind tunnel test results and directional wind speed data.

b.   Nationally accepted standards should be developed for estimating wind loads in the design of tall buildings.  The development of performance standards for estimating wind loads should consider:  (1) appropriate load combinations and load factors, including performance criteria for static and dynamic behaviour, based on both ultimate and serviceability limit states;  and (2) validation of wind load provisions in prescriptive design standards for tall buildings, given the universally acknowledged use of wind tunnel testing and associated performance criteria.  Limitations to the use of prescriptive wind load provisions should be clearly identified in codes and standards.

The standards development work can begin immediately to address many of the above needs.  The results of those efforts should be adopted in practice as soon as they become available.  The research that will be required to address the remaining needs also should begin immediately and results should be made available for standards development and use in practice.  Affected National Standard:  ASCE-7.  Model Building Codes:  The standard should be adopted in model building codes by mandatory reference to, or incorporation of, the latest edition of the standard.

NIST WTC Recommendation 3.

NIST recommends that an appropriate criterion be developed and implemented to enhance the performance of tall buildings by limiting how much they sway under lateral load design conditions (e.g. winds and earthquakes).  The stability and safety of tall buildings depend upon, among other factors, the magnitude of building sway or deflection, which tends to increase with building height.  Conventional strength-based methods, such as those used in the design of the WTC towers, do not limit deflections.  The deflection limit state criterion, which is proposed here is in addition to the stress limit state and serviceability requirement;  it should be adopted either to complement the safety provided by conventional strength-based design or independently as an alternate deflection-based approach to the design of tall buildings for life safety.  The recommended deflection limit state criterion is independent of the criterion used to ensure occupant comfort, which is met in current practice by limiting accelerations (e.g. in the 15 to 20 milli-g range). Lateral deflections, which already are limited in the design of tall buildings to control damage in earthquake-prone regions, should also be limited in non-seismic areas.*

[ * F-22  Analysis of baseline performance under the original design wind loads indicated that the WTC towers would need to have been between 50 % and 90 % stiffer to achieve a typical drift ratio used in current practice for non-seismic regions, though not required by building codes.  Limiting drift would have required increasing exterior column areas in lower stories and/or significant additional damping.]

Affected National standards:  ASCE-7, AISC Specifications, and ACI 318.  Model Building Codes:  The standard should be adopted in model building codes by mandatory reference to, or incorporation of, the latest edition of the standard.

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Tags: 2005 & 2008 Final Reports of the U.S. National Institute of Standards & Technology (NIST) on the 9-11 World Trade Center Building 1 2 & 7 Collapses, 2005 NIST WTC RECOMMENDATIONS, A robust integrated predictive capability should be developed validated and maintained to routinely assess the vulnerability of whole structures, ACI 318, Affected Standards, AISC Specifications, analytical tools to predict potential collapse mechanisms, and our operation maintenance and emergency response procedures, Arab Gulf Region, As far as the British Standards Institution is concerned ... 9-11 never happened, As such a high level of performance is expected ... indeed demanded ... of a Sustainable Building, ASCE-7, bomb blasts, Brazil Russia India China and South Africa (BRICS), British Standard BS 9999 - Code of Practice for Fire Safety in the Design Management and Use of Buildings, Built Environment, capacity to redistribute loads from impact and fire damaged structural components and sub-systems to undamaged components and sub-systems, China, CJ Walsh, Client Organizations, Clients/Client Organizations in ALL countries, comprehensive design rules and practice guides, computer models and analysis procedures for use in routine design practice, Design Wind Speeds must be increased accordingly for ALL Buildings, Disproportionate Damage, earthquakes, Europe, evaluate the safety implications of these Recommendations for their existing inventory of buildings, evaluation criteria methodology and tools for assessing the vulnerability of structures to progressive collapse, Fire Engineering Design, Fire Safety, Fire Serviceability Limit States, fire-induced progressive collapse, FireOx International, fires, gas explosions, GROUP 1. 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supported by analytical design tools and practical design guidance - to reliably predict the potential for complex failures in structura, NIST strongly urges that immediate and serious consideration be given to these Recommendations by the building and fire safety communities, NIST WTC Recommendation 1, NIST WTC Recommendation 2, NIST WTC Recommendation 3, NIST's Recommendations on the 9-11 WTC Building Collapses, North America, performance-based criteria for abnormal loads and load combinations, precisely because I am an Architect a Fire Engineer and a Technical Controller, primary structural systems should provide alternate paths for carrying loads in case certain components fail, Progressive collapse is addressed only in a very limited way in practice and by codes and standards, Recommendation 2 would certainly need to be understood and implemented within today's additional design constraints, relevant to evaluating the baseline capacity of the structures to withstand abnormal events such as major fires or impact damage, Resilience to Severe Weather Events, Russia, Since shortly after my visit to Lower Manhattan in mid-October 2001, so catastrophic was the failure exposed on that fateful day (11 September 2001), some of Recommendations apply specifically to Tall and Very Tall Buildings, South Africa, Structural Fire Engineering, Sustainable Building, Sustainable Climate Change Adaptation, Sustainable Fire Engineering, Sustainable Fire Engineering must be 'reliability-based', take the steps necessary to mitigate any unwarranted risks without waiting for changes to occur in codes standards and practices, The capability to prevent progressive collapse due to abnormal loads should include, The codes and standards may vary from the WTC Recommendations but satisfy their intent, the core columns in the WTC towers lacked sufficient redundant paths for carrying gravity loads, The deflection limit state criterion which is proposed here is in addition to the stress limit state and serviceability requirement, the design of structural systems to mitigate the effects of those hazards should be improved to enhance structural integrity, the effects of credible hazards, the estimation of 'component' wind effects by integrating wind tunnel data with wind speed and direction information, the estimation of 'resultant' wind effects using load combination methods, The failure analysis capability should include all possible complex failure phenomena that may occur under multiple hazards, the flawed and out-of-date practices and procedures of conventional fire engineering, the General Public in ALL of our societies, The implications arising from implementation are much too hard to digest, the magnitude of building sway or deflection which tends to increase with building height, the nature of hurricane wind profiles, the response has ranged from mild interest to complete apathy and even to vehement antipathy, the selection of design wind speeds and directionality, The stability and safety of tall buildings, The standards for estimating the load effects of potential hazards, their implementation would make buildings safer for occupants and emergency responders in future emergencies, there is no use trying to hide the fact that progress on implementing the NIST Recommendations has been lamentably slow, they do not account for building-specific aerodynamic effects, This capability would also assist in investigations of building failure, This is especially important in buildings where structural components support unusually large floor areas, United States of America, unlike conventional fire engineering which is yet aimlessly wandering around in pre-historic caves, Vested Interests, which I think is an inexcusable and unforgivable technical oversight !, While the WTC towers eventually collapsed, Wind loads specified in current prescriptive codes may not be appropriate for the design of very tall buildings, Wind loads were a major factor in the design of the WTC tower structures, World Trade Center Incident (9-11)

‘Priory Hall’, Fire Engineering & Protecting Society’s Interests ??

2011-10-23:  Further to my post, dated 18 October 2011 …

Has anybody’s interests been protected by what has happened at the ‘Priory Hall’ Apartment Development, in Donaghmede, Dublin 13 ?   NO.

Now that the buildings there have been completed … will it be possible to effectively repair the most serious fire protection, sound transmission and energy conservation problems with the buildings ??   NO.

At the heart of these problems lie Fundamental Design and Construction Flaws … because, back in the 1990′s and early 2000′s, indigenous builders of simple two storey semi-detached houses suddenly became ‘developers’ of apartment complexes … and these were very different building animals altogether, requiring a degree of technical competence well beyond their reach.  And, of course, during the actual construction process everything had to be finished ‘yesterday’, and as cheaply as possible (a policy of cheap product substitution was the un-stated national norm !).  In fact, so many corners were cut on Irish Building Sites, at the time, that we should refer to almost the entire construction output from this era as: The Celtic Tiger Round Towers !

And guess who is going to carry out the Corrective/Repair/Refurbishment Works at ‘Priory Hall’ ?   The very same Construction Organization which created the mess in the first place !!   Can you believe it ??

Furthermore … once these Corrective/Repair/Refurbishment Works are eventually finished … the performance of the Fire Protection Measures in ‘Priory Hall’ will still be compromised, because you can only do so much, physically, when a building is completed.  BUT … it would be possible to achieve a Proper Level of Fire Safety in ‘Priory Hall’ … by installing a Fire Suppression System (sprinklers or mist) throughout the development.  That’s what it will take !!

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WHO IS PROTECTING SOCIETY ?

So extensive is the damage caused by fire … throughout Europe … that not all of the Direct and Indirect Fire Losses have yet been identified.

Pause, to consider this definition …

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.

And this means, of course, that our current Fire Loss Data and Statistics are unreliable.

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It is not well known, or widely publicised, that the Fire Safety Objectives of Building Regulations are limited to protecting building occupants.  The Objectives are only concerned with protecting property, insofar as it is relevant to the protection of those building occupants.

Can you image the look of astonishment on the face of a Managing Director, after his/her factory has been entirely destroyed by a fire, when told by a fire consultant …

” We complied with Part B of the Building Regulations, and here is your Fire Safety Certificate to prove it”  ??

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What should be happening instead ?

     1.  Fire Engineering Design & Practice cannot … and must not … be concerned merely with the ‘cost-effective’ compliance with minimal (which they most certainly are !) Fire Safety Objectives mandated by Building Legislation.

     2.  To properly protect the interests of Society and Clients/Client Organizations … Fire Engineering Design & Practice must also take into account: Safety at Work Legislation; Rights, Equality & Anti-Discrimination Legislation; Environmental Impact Legislation; Public Procurement Legislation; Product Liability Legislation; etc., etc.

     3.  There is an evolving realization in Ethical Fire Engineering Design & Practice, however, that there is still a significant gap to be bridged.  There is no legislation (effective, or otherwise) yet in place, anywhere, which deals with such issues as …

• Resistance to Fire-Induced Progressive Collapse – as very strongly recommended in the 2005 & 2008 U.S. NIST Final Reports on the 9-11 World Trade Center Building 1, 2 & 7 Collapses ;
• Protection of Vulnerable Building Users in ‘Situations of Risk’ – as required, for example, by Article 11 of the UN Convention on the Rights of Persons with Disabilities (CRPD) ;
• Safety of Firefighters/Rescue Teams – as specified in Basic Requirement for Construction Works No.2, in Annex I of European Union Construction Product Regulation 305/2011 ;
• Adaptation to Climate Change and Severe Weather Events – the Developed World Economies appear to have no interest, whatsoever, in these issues ;
• Sustainable Human & Social Development !

     4.  We must clearly distinguish, therefore, between the Fire Safety Objectives of Building Regulations/Codes … and Project-Specific Fire Engineering Design Objectives.  This difference must be fully understood by the Fire Engineer himself/herself … and then, in all circumstances, properly explained to the Client/Client Organization.

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In designing a Building for conditions of fire, and its aftermath … which may take place at any time during the Life Cycle of that Building … Project-Specific Fire Engineering Design Objectives should cover the following spectrum of concerns … in order to properly protect the interests of Society and our Clients/Client Organizations …

  -   Protection of the Health & Safety of All Building Users … including People with Activity Limitations (2001 WHO ICF), visitors to the building who may be unfamiliar with its layout, and contractors or product/service suppliers temporarily engaged in work or business transactions on the premises ;

  -   Protection of Property … including the building, its contents, and adjoining or adjacent properties … from loss or damage ;

  -   Protection of the Health & Safety of Firefighters, Rescue Teams & Other Emergency First Response Personnel ;

  -   Facility, Ease & Efficient Cost of Carrying Out Effective Reconstruction, Refurbishment or Repair Works after a Fire ;

  -   Sustainability of the Human Environment (social, built, virtual, economic, …) – including Fitness for Intended Use and Life Cycle Costing of fire engineering related products, components, systems, etc., fixed, installed or incorporated in the building ;

  -   Protection of the Natural Environment from Harm, i.e. Adverse Impacts.

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CRIMINAL RESPONSE TO 1981 DUBLIN STARDUST TRAGEDY !

As I write … a stampede has just commenced by the various Construction-Related Professional Institutes and Organizations … to demand closer independent monitoring of what is happening on Irish Building Sites.  Far too little … and definitely, far too late !   Back in the early 1990′s, everybody stood by … and co-operated with the installation of an entirely ineffective and dysfunctional system of National Building Control in Ireland … which, let us not forget, survives intact to this day … while, at the same time, the strong long-established and well-resourced Building Control Sections in Dublin and Cork were being quietly dismantled.

The Minister for the Environment, Community & Local Government, Mr. Phil Hogan T.D. … is also chirping in from his ivory tower !

Crocodile Tears !!

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Take a Fire Safety Certificate for a Building, for example …

With or Without Conditions … this document confirms that the Local Building Control/Fire Authority is satisfied that the Design Documentation for that building shows proper compliance with the Legal Requirements of Part B of the Irish Building Regulations.

Focus in on the relevant wording of a Fire Safety Certificate, which is as follows …

‘ … hereby certify that the works or building to which the application relates, will, if constructed in accordance with the plans, calculations, specifications and particulars submitted, comply with the requirements of Part B of the Second Schedule to the Building Regulations 1997 to 2008.’

Fire Safety Related Inspections of Construction Projects are not carried out by Competent Local Authority Personnel, or by Competent Independent Technical Controllers.  Therefore … a Fire Safety Certificate cannot give, and is not intended to give, any indication with regard to Fire Safety in the Completed Building.  The ‘Fire’ Establishment in Ireland knows full well that this is the situation !

Is this any sort of a reasonable, caring or competent response to the 1981 Stardust Discotheque Fire Tragedy in Dublin ??

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END

Tags: 'Priory Hall' Apartment Development in Donaghmede Dublin 13, 'Priory Hall' Fire Engineering & Protecting Society's Interests ??, ... and Project-Specific Fire Engineering Design Objectives, a Fire Safety Certificate cannot give and is not intended to give any indication with regard to Fire Safety in the Completed Building, a policy of cheap product substitution was the un-stated national norm !, a stampede has just commenced by the various Construction-Related Professional Institutes and Organizations, Adaptation to Climate Change and Severe Weather Events, after his/her factory has been entirely destroyed by a fire, also chirping in from his ivory tower, and co-operated with the installation of an entirely ineffective and dysfunctional system of National Building Control in Ireland, and must not ... be concerned merely with the 'cost-effective' compliance with minimal Fire Safety Objectives mandated by Building Legislation, Article 11 of the UN Convention on the Rights of Persons with Disabilities (CRPD), as cheaply as possible, as very strongly Recommended in the 2005 & 2008 U.S. NIST Final Reports on the 9-11 World Trade Center Building 1 2 & 7 Collapses, At the heart of these problems lie Fundamental Design and Construction Flaws, at the same time the strong long-established and well-resourced Building Control Sections in Dublin and Cork were being quietly dismantled, back in the 1990's and early 2000's indigenous builders of simple two storey semi-detached houses suddenly became 'developers' of apartment complexes, Back in the early 1990's everybody stood by ..., Basic Requirement for Construction Works No.2 in Annex I of European Union Construction Product Regulation 305/2011, because you can only do so much physically when a building is completed, Built Environment, Can you image the look of astonishment on the face of a Managing Director, Client Organizations, Climate Change Adaptation, Competent Independent Technical Controllers, components systems etc. fixed installed or incorporated in the building, contractors or product/service suppliers temporarily engaged in work or business transactions on the premises, CRIMINAL RESPONSE TO 1981 DUBLIN STARDUST TRAGEDY !, Crocodile Tears !!, Developed World Economies appear to have no interest whatsoever in these issues, during the actual construction process everything had to be finished 'yesterday', Environmental Impact Legislation, EU, european union, Facility Ease & Efficient Cost of Carrying Out Effective Reconstruction Refurbishment or Repair Works after a Fire, Fire Engineering Design, Fire Engineering Design & Practice cannot ... and must not, Fire Engineering Design & Practice must also take account of Safety at Work Legislation, Fire Safety, Fire Safety Certificate for a Building, Fire Safety Related Inspections of Construction Projects are not carried out by Competent Local Authority Personnel, FireOx International, Fitness for Intended Use and Life Cycle Costing of fire engineering related products, Focus in on the relevant wording of a Fire Safety Certificate, guess who is going to carry out the Corrective/Repair/Refurbishment Works at 'Priory Hall' ?, human environment, if constructed in accordance with the plans calculations specifications and particulars submitted, In designing a building for conditions of fire and its aftermath, In order to properly protect the interests of Society and our Clients/Client Organizations, insofar as it is relevant to the protection of building occupants, International Legal Instrument, Ireland, Is this any sort of a reasonable caring or competent response to the 1981 Stardust Discotheque Fire Tragedy in Dublin ??, it would be possible to achieve a Proper Level of Fire Safety in 'Priory Hall' ... by installing a Fire Suppression System, not all of the Direct and Indirect Fire Losses have yet been identified, our Clients, our current Fire Loss Data and Statistics are unreliable, People with Activity Limitations (2001 WHO ICF), Personnes à Performances Réduites (2001 WHO ICF), Product Liability Legislation, Protection of Property, Protection of the Health & Safety of All Building Users, Protection of the Health & Safety of Firefighters Rescue Teams & Other Emergency First Response Personnel, Protection of the Natural Environment from Harm i.e. Adverse Impacts, Protection of Vulnerable Building Users in 'Situations of Risk', Public Procurement Legislation, requiring a degree of technical competence well beyond their reach, Resistance to Fire-Induced Progressive Collapse, Rights Equality & Anti-Discrimination Legislation, Safety of Firefighters/Rescue Teams, So extensive is the damage caused by fire ... throughout Europe, so many corners were cut on Irish Building Sites at the time, Sustainability Implementation, Sustainability of the Human Environment (social - built - virtual - economic ...), Sustainable Fire Engineering, Sustainable Human & Social Development, Technical Control of Construction, The 'Fire' Establishment in Ireland knows full well that this is the situation !, the Design Documentation for that building shows proper compliance with the Legal Requirements of Part B of the Irish Building Regulations, the Fire Safety Objectives of Building Regulations are limited to protecting building occupants, The Minister for the Environment Community & Local Government Mr. Phil Hogan T.D., The Objectives are only concerned with protecting property, the performance of the Fire Protection Measures in 'Priory Hall' will still be compromised, The very same Construction Organization which created the mess in the first place !!, then in all circumstances properly explained to the client/client organization, There is an evolving realization in Ethical Fire Engineering Design & Practice, There is no legislation (effective or otherwise) yet in place anywhere which deals with such issues as ..., there is still a significant gap to be bridged, these were very different building animals altogether, This difference must be clearly understood by the Fire Engineer himself/herself, this document confirms that the Local Building Control/Fire Authority is satisfied, to demand closer independent monitoring of what is happening on Irish Building Sites, To properly protect the interests of Society and Clients/Client Organizations, United Nations Convention on the Rights of Persons with Disabilities, visitors to the building who may be unfamiliar with its layout, We must distinguish between the Fire Safety Objectives of Building Regulations/Codes, we should refer to almost the entire construction output from this era as: The Celtic Tiger Round Towers, What should be happening instead ?, which may take place at any time during the Life Cycle of that Building, WHO IS PROTECTING SOCIETY ?, will it be possible to effectively repair the most serious fire protection sound transmission and energy conservation problems

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

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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.

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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.

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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.

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END  (for now, but to be continued soon !)

Tags: 'Priory Hall' is the Tip of the Iceberg !, 1. Informed Consent of Apartment Owners and Occupants, 2. 'As Constructed' Drawings & Specification of Entire Development, 2005 Final Report of the U.S. National Institute of Standards & Technology (NIST) on the 9-11 World Trade Center Tower Collapses, 3. Failures to Properly Comply with Current Building Regulation Requirements A to M (Second Schedule to Irish Building Regulations), 4. The Necessary Corrective/Repair/Refurbishment Works, 5. Independent Technical Control of Construction Works, 6. Meeting & Discussion with Other Owners/Occupants, 7. Commencement of Corrective/Repair/Refurbishment Works, A large 'can of worms' has recently been opened in Ireland, a Private Multi-Storey Apartment Development, a satisfactory level of long-term safety protection convenience and comfort will be provided for the occupants of Priory Hall, As they have a large vested interest in the problems of Priory Hall ... either directly or indirectly, Become very very suspicious whenever there is a use of or reference to the term 'Substantial Compliance' !!, before any necessary Corrective/Repair/Refurbishment Works are carried out, Beware of decorative solutions which look good to a superficial visual inspection in ambient conditions ... but don't actually solve anything, Building Regulation Approved Documents for England and Wales, Built Environment, CHECK the adequacy of the Detailed Drawings and Specification, CHECK the adequacy of the Independent Technical Control actually being undertaken, CHECK the adequacy of the Proposed Method of Independent Technical Control during execution of the Corrective/Repair/Refurbishment Works, CHECK the adequacy of this Detailed Schedule ... ensure that it is Comprehensive, CHECK the adequacy of this Full Detailed Information, Client Organizations, Construction Sites are one of the most hazardous 'workplaces' in this country, Demand only Category A Construction Execution of the necessary Corrective/Repair/Refurbishment Works, demand that an 'As Constructed' Survey of the Entire Development be carried out immediately, Demand that the Informed Consent of the Owner/Occupant of an Apartment is required in writing, Demand to be updated regularly, Demand to see a Detailed Schedule of the many failures to properly comply with current Building Regulation Requirements, Demand to see Full Detailed Information in the form of annotated drawings and descriptive texts, Department of the Environment Community and Local Government (DECLG), depending on the type of project occasional or frequent inspections above ground level, Do not act alone ... meet the other Owners/Occupants and discuss issues with them, Dublin City Council (DCC), Energy Performance of Buildings, fire evacuation of people with activity limitations, Fire Safety, fire service support infrastructure, FIXING 'PRIORY HALL' IN DUBLIN, Fixing 'Priory Hall' in Dublin - Practical Solutions Needed Now !, FUBAR, has been designed (for want of a better word) in a chaotic haphazard and malevolent way, has been happening for twenty years all over the country, how do we fix Priory Hall as the situation now presents itself, I have been listening intently to Joe Duffy, Ireland, Ireland's current dysfunctional approach to the development of Our(!) Built Environment, Joe Duffy on the RTE Radio 'Liveline' Programme at lunchtime, Joe is being very cautious because he cannot quite believe his ears, mandatory inspections by competent local authority personnel at the foundation level and drainage level of all building sites, necessary to effectively solve the serious problems in the Development, no assurances or undertakings should be accepted on face value, outside of the major urban areas having Legal Building Bye-Laws and Effective Building Control, Parts A to M in the Second Schedule to the Building Regulations as amended, People with Activity Limitations (2001 WHO ICF), Personnes à Performances Réduites (2001 WHO ICF), PRACTICAL SOLUTIONS NEEDED NOW, Share and collate all available information together, since the introduction of Legal National Building Regulations with NO Effective Building Control in 1991, Structural Fire Engineering, Sustainable Design International, Technical Control of Construction, the big surprise for me is that there is so much public shock, the biggest joke of all, the Common Areas of your Block, the exact nature timetable and phasing of all of the Corrective/Repair/Refurbishment Works, The following list of practical suggestions is addressed to the Owners and Occupants of Apartments in Priory Hall, The Guidance Texts in Technical Guidance Document B: 'Fire Safety' are merely that ... GUIDANCE, the social wellbeing of the local community there can be restored, the structural performance of buildings during conditions of fire and the 'cooling phase' immediately afterwards, the sum of the many resources both human and material required to repair sub-standard construction throughout Ireland, the tales and anecdotes about Irish Building Sites during the Celtic Tiger Years, the unfolding harrowing events for occupants in 'Priory Hall' Donaghmede Dublin 13, This guidance is not infallible ... and in a few respects is entirely inadequate, this is one of the professional services we provide at Sustainable Design International, throughout the full extent of the Approach Routes to your Block Entrances and Exits, to end up in exactly the sort of mess which we are all now witnessing in North County Dublin, United States of America, Visit the Construction Site Office regularly, what has been happening in the Irish Construction Industry during the boom years, will count as a positive contribution towards the economic indicator of GDP (Gross Domestic Product)

Disability Access Certificates (DAC’s) in Ireland – Confused ??

2011-09-01:  To say, bluntly, that there is confusion out there … at every level … would be a mild understatement !   Yes, the Disability Access Certificate (DAC) & Revised DAC Process is new … but that cannot explain what is happening … or, more precisely, what is not happening.

BUT … before jumping in at the deep end and examining the existing and operative Part M of the Irish Building Regulations … let me just mention, very briefly, two wider legal ‘niceties’ concerning Accessibility of Buildings for People with Disabilities …

     1.  The Black Hole between Building Regulations and Equality Law

The definition of People with Disabilities in the existing Part M is limited.  It is inadequate.  Compare, now, that definition with the definition of Disability in Irish Equality Legislation … which is the complete opposite, being very wide in scope.  A deep chasm exists between the two.  Check each of them out for yourself !   And because few people are aware of this chasm … a better description of that large space might be a Black Hole.

However, the clear consequence of the Black Hole for building owners … and building designers alike … is that the ‘act’ of merely going through the motions with regard to compliance with Part M … and being satisfied with getting ‘the’ piece of paper, i.e. a Disability Access Certificate … will, without any shadow of a doubt, open the building owner to a complaint under Equality Law.  And when a building owner encounters this sort of problem … who will he, or she, hunt down for an explanation ??

Client Organizations beware … prevention is a far better strategy !!   Check out the Level of Accessibility Performance required to avoid complaints under Equality Legislation.

[ You should also consider the following ... the Health & Safety Authority in Ireland is doing absolutely nothing to ensure that Workplaces are Accessible ... a requirement contained in all of the European Union (EU) Safety at Work Directives and the Irish National Legislation implementing those Directives.  So, also cross check the Level of Accessibility Performance required to comply with Safety at Work Legislation.  Compliance with Part M is not sufficient ! ]

     2.  European Union Ratification of the 2006 United Nations Convention on the Rights of Persons with Disabilities (CRPD)

For a sizeable group of vulnerable people in every EU Member State, the sole route of access to many, if not most, of the Human and Social Rights set down in the 1948 Universal Declaration of Human Rights (UDHR) is the UN Convention on the Rights of Persons with Disabilities (CRPD) … which became an International Legal Instrument on 3 May 2008, and was ratified by the European Union on 23 December 2010.  That is precisely why Accessibility is such a critical component of the 2006 UN Convention !

Articles 31 & 33 of the 2006 UN Convention on the Rights of Persons with Disabilities – together – mandate that Accessibility Implementation is taken seriously … that it is competent and effective … and, most importantly, that independent monitoring and verification is a fundamental part of the process.

Ireland has not yet ratified the UN CRPD.  And, as far as our National Authorities Having Jurisdiction (AHJ’s) are concerned … everything in the garden is beautiful … Ireland is doing just great and nothing much needs to be altered in our laws, administrative provisions or resourcing … to allow Ireland to ratify the Convention, and then properly implement it.  Nothing could be further from the truth !

In Order to Protect your Organization and its many interests … Your Policy and Decision Makers, in Ireland, should study the implications flowing directly from EU Ratification of the UN CRPD … and then, the various Articles of the UN Convention should be examined and properly implemented … insofar as those Articles are relevant to you and your organization’s activities.  See my earlier post, dated 5 February 2011.

To date … the quality of Accessibility Implementation in Irish Buildings has been dreadful !!   For important reasons … which all parties involved should fully understand … this situation is longer acceptable.

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Disability Access Certificates (DAC’s) & Part M

The submission of sufficient, quality information, i.e. detailed design documentation, at Disability Access Certificate (DAC) Application Stage typically signals the following to an experienced technical controller …

• The intent of the Applicant, and the Agent(s) acting on his/her/their behalf, with regard to properly and satisfactorily complying with the relevant building legislation, i.e. Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Irish Building Regulations ;  and
• In the absence of an inspection by the Building Control Authority (BCA) during actual construction … whether or not it is likely that the completed works will match the DAC certified design documentation with regard to Accessibility Performance.

From the beginning, it is necessary to distinguish between Access and Accessibility.

To be written in stone when International Standard ISO 21542 is soon published … the components of Building Accessibility comprise …

• Approach to the building ;
• Entry ;
• Use of the building, its services and facilities ;
• Egress from the building (during normal conditions) ;
• Removal from the vicinity of the building (during normal conditions) ;

and

• Evacuation from the building (during, for example, a fire emergency) ;
• Safe Movement to a ‘place of safety’ (during, for example, a fire emergency), which is remote from the building.

This is also a useful guideline with regard to segregating those aspects of Accessibility Design which relate to Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Irish Building Regulations, and which should be considered in any application for a Disability Access Certificate (DAC) … and those, after ‘and‘ … which relate to Part B: ‘Fire Safety’, and which should be considered in every application for a Fire Safety Certificate (FSC).

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The 2000 Building Regulations (Amendment) Regulations … Statutory Instrument No. 179 of 2000 … elaborate the relevant Irish Building Legislation concerning building access, i.e. Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Building Regulations …

“Access and Use

M1     Adequate provision shall be made to enable people with disabilities to safely and independently access and use a building.

Sanitary Conveniences

M2     If sanitary conveniences are provided in a building, adequate provision shall be made for people with disabilities.

Audience or Spectator Facilities

M3     If a building contains fixed seating for audience or spectators, adequate provision shall be made for people with disabilities.

Definition for This Part

M4     In this Part, ‘people with disabilities’ means people who have an impairment of hearing or sight or an impairment which limits their ability to walk, or which restricts them to a wheelchair.

Application of This Part

M5     Part M does not apply to works in connection with extensions to and the material alterations of existing dwellings, provided that such works do not create a new dwelling.”

My Note 1:  In order to safely and independently use a building … it is also necessary, under normal conditions, to use the egress routes of a building.

My Note 2:  The limited definition of ‘people with disabilities’ in Requirement M4 does not include, for example, a person without arms … or those people with a mental, cognitive or psychological impairment.

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Technical Guidance Document M (2000, re-printed in 2005) provides guidance in relation to Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Irish Building Regulations.  TGD M was issued by the Department of the Environment, under Article 7 of the 1997 Building Regulations … Statutory Instrument No. 497 of 1997 … which states …

” 7.     (1)  The Minister may publish, or arrange to have published on his behalf, documents to be known as ‘technical guidance documents’ for the purpose of providing guidance with respect to compliance with the requirements of any of the provisions of the Second Schedule.

          (2)  Subject to the provisions of sub-article (3), where works or a building to which these Regulations apply is or are designed and constructed in accordance with any guidance contained in a technical guidance document, this shall, prima facie, indicate compliance with the relevant requirements of these Regulations.

          (3)  The provisions of any guidance contained in a technical guidance document published under sub-article (1) concerning the use of a particular material, method of construction or specification, shall not be construed as prohibiting compliance with a requirement of these Regulations by the use of any other suitable material, method of construction or specification.”

My Note 3:  Since the introduction of national legal building legislation in the early 1990′s, the Irish Building Regulations have a Functional Format, as required by European Union (EU) Law.  In other words, satisfactory compliance with short functional statements is mandated by law … and provided the requirements of those short statements are properly shown to be complied with, it is entirely optional as to which materials, methods of construction, standards and other specifications (including technical specifications) are used.  In this way, the free movement of products and services within the EU is facilitated and encouraged while, at the same time, technical barriers to trade are avoided.

My Note 4:  For the convenience of readers, the short functional statements mandated by law are reproduced, in a shaded box, at the beginning of each of the Technical Guidance Documents.  The Guidance Texts in each Technical Guidance Document, however, are not Prescriptive Regulations.  These texts are merely an indicator of what is likely to be suitable for the purposes of compliance with the Regulations … they are, prima facie (i.e. on ‘first appearance’ only), an indication of compliance ;  they are not ‘deemed-to-satisfy’ the Requirements of Part M.

My Note 5:  Where gaps are identified in the guidance texts of Technical Guidance Document M … and in the absence of an Irish National Standard on Building Access or Accessibility … a suggested hierarchy of approach should be to source an appropriate European Standard (EN) or, if such a standard does not yet exist, then an appropriate International Standard (ISO), or then a National Standard of any country which is a contracting party to the Agreement on the European Economic Area (EEA) which provides in use an appropriate level of Access/Accessibility Performance (refer to Part D of the Second Schedule to the Building Regulations).  In the unlikely absence of any of the above, an appropriate Design Guidance Document – national or otherwise – should be referenced which provides in use an appropriate level of Access/Accessibility Performance.

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Our Organization – Sustainable Design International – provides an independent (and confidential) Accessibility Monitoring and Verification Service.

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END

Tags: 2000 Building Regulations (Amendment) Regulations ... Statutory Instrument No. 179 of 2000, A deep chasm exists between the two, a National Standard of any country which is a contracting party to the Agreement on the European Economic Area (EEA), a requirement contained in all of the European Union (EU) Safety at Work Directives and the Irish National Legislation implementing those Directives, a suggested hierarchy of approach, Accessibility Implementation is taken seriously ... that it is competent and effective ... and that independent monitoring and verification is a fundamental part of the process, Accessibility of buildings for people with disabilities, Accessibility-for-All, an experienced technical controller, Approach to the building, as far as our National Authorities Having Jurisdiction (AHJ's) are concerned ... everything in the garden is beautiful, because few people are aware of this chasm ... a better description of that large space might be a Black Hole, being satisfied with getting 'the' piece of paper - a Disability Access Certificate, Built Environment, Check out the Level of Accessibility Performance required to avoid complaints under Equality Legislation, Client Organizations, Client Organizations beware ... prevention is a far better strategy !!, Compliance with Part M is not sufficient !, cross check the Level of Accessibility Performance required to comply with Safety at Work Legislation, Department of the Environment Heritage and Local Government (DEHLG), Disability Access Certificate (DAC) Application Stage, Disability Access Certificates (DAC's) & Part M, Disability Access Certificates (DAC's) in Ireland - Confused ??, Egress from the building (during normal conditions), Entry, EU, EU Ratification of the 2006 United Nations Convention on the Rights of Persons with Disabilities (CRPD), European Standard (EN), european union, Evacuation from the building (during a fire emergency), examining the existing and operative Part M of the Irish Building Regulations, Fire Safety Certificate (FSC), human environment, In Order to Protect your Organization and its many interests, In the absence of an inspection by the Building Control Authority (BCA) during actual construction, Independent Accessibility Verification, International Legal Instrument, International Standard (ISO), Ireland, Ireland has not yet ratified the UN CRPD, it is necessary to distinguish between Access and Accessibility, Nothing could be further from the truth !, Our Organization provides an independent (and confidential) Accessibility Monitoring and Verification Service, Part B: 'Fire Safety', Part D of the Second Schedule to the Building Regulations, Part M: 'Access for People with Disabilities' of the Second Schedule to the Irish Building Regulations, People with Activity Limitations (2001 WHO ICF), Personnes à Performances Réduites (2001 WHO ICF), prima facie (i.e. on 'first appearance' only), providing guidance with respect to compliance, re-printed in 2005), Safe Movement to a ‘place of safety’ which is remote from the building, shall not be construed as prohibiting compliance with a requirement of these Regulations by the use of any other suitable material method of construction or specification, Social Environment, Sustainable Design International, Sustainable Human & Social Development, technical barriers to trade are avoided, Technical Control of Design and Construction, Technical Guidance Document M (2000, That is precisely why Accessibility is such a critical component of the 2006 UN Convention, the 'act' of merely going through the motions with regard to compliance with Part M, The Black Hole between Building Regulations and Equality Law, the clear consequence of the Black Hole for building owners ... and building designers alike, the components of Building Accessibility comprise, the definition of Disability in Irish Equality Legislation ... which is the complete opposite being very wide in scope, The definition of People with Disabilities in the existing Part M is limited, the Disability Access Certificate (DAC) & Revised DAC Process is new, the free movement of products and services within the EU is facilitated and encouraged, The Guidance Texts in each Technical Guidance Document are not Prescriptive Regulations, the Health & Safety Authority in Ireland is doing absolutely nothing to ensure that Workplaces are Accessible, The intent of the Applicant with regard to properly and satisfactorily complying with the relevant building legislation, the Irish Building Regulations have a Functional Format, the sole route of access to many of the Human and Social Rights set down in the 1948 Universal Declaration of Human Rights (UDHR), the various Articles of the UN Convention should be examined and properly implemented, they are not 'deemed-to-satisfy' the Requirements of Part M, this situation is longer acceptable, To be written in stone when International Standard ISO 21542 is soon published, To date ... the quality of Accessibility Implementation in Irish Buildings has been dreadful !!, To say that there is confusion out there ... at every level ... would be a mild understatement !, two wider legal 'niceties' concerning Accessibility of Buildings for People with Disabilities, United Nations Convention on the Rights of Persons with Disabilities, Use of the building its services and facilities, was ratified by the European Union on 23 December 2010, whether or not it is likely that the completed works will match the DAC certified design documentation with regard to Accessibility Performance, which became an International Legal Instrument on 3 May 2008, which provides in use an appropriate level of Access/Accessibility Performance, Your Policy and Decision Makers in Ireland should study the implications flowing directly from EU Ratification of the UN CRPD

2011 IFE International Fire Conference & AGM in Cardiff, Wales

2011-07-17:  On 6th & 7th July last … in Cardiff, the Capital City of Wales … the Institution of Fire Engineers (IFE) held its Annual General Meeting (AGM), followed by a very well attended 1½ Day International Fire Conference.  Participants came from as far away as Australia, New Zealand, Malaysia, Taiwan, Hong Kong (in China), Canada, U.S.A., Nigeria and Switzerland.  A large, vocal group of delegates from The Netherlands also attended … and of course, there were many people from these islands … Ireland and Great Britain … the Irish Isles !

For me, it was an enjoyable few days in Cardiff.

The Immediate Past President of the IFE, Mr John Woodcock, had initiated an important programme of activities during his 2010/2011 Term of Office on the theme of ‘Fire Engineering & Sustainability’.  The New IFE President for 2011/2012, Mr. H.G. (Hao-Giang) Tay, has stated that he will continue this work with enthusiasm.

This brings me very neatly to the reason for my attendance at the Cardiff ‘Gig’.  I had been invited by HG Tay to make a presentation on ‘Sustainable Fire Engineering’.  This, I was very pleased and honoured to do.

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” The audience found the conference extremely valuable and I had many delegates who spoke to me specifically about how good the conference was and the high standard of the presentations.  The number of questions on each presentation was a testament to the interest of the audience.

The subject is of such importance that we really need to make sure the voice of the profession is firmly planted in all decision-making on design, protection and management of buildings.”

[Short Extract, Letter from HG Tay, International IFE President, dated 27 July 2011]

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2011 IFE Cardiff Overhead Presentation

CJ Walsh: “Sustainable Fire Engineering IS THE FUTURE !”

Click the Link Above to read and/or download PDF File (3.98 Mb)

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In order to properly protect the interests of Society and our Clients/Client Organizations … and to effectively realize a Safe and Sustainable Built Environment in the 21st Century … it is necessary, in designing a building for fire and its immediate aftermath, for the Fire Engineer to develop Project-Specific Fire Engineering Design Objectives … which must never be confused with the minimal Fire Safety Objectives mandated in Building and Fire Regulations and Codes.

Sustainable Fire Engineering is concerned with far more than compliance with Legislation !   For this reason, a Fire Engineering Code of Ethics is essential.

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Ethically Based Sustainable Fire Engineering must also consider the following issues, which are relevant to Today’s Human Environment :

1. Sustainable Human & Social Development.
2. Adaptation to Climate Change and Severe Weather Events … not less than a recurrence interval of 100 years should be used in design, always bearing in mind that the minimum Building Life Cycle for a Sustainable Building is 100 years.
3. Resistance to Fire-Induced Progressive Building Collapse and Disproportionate Damage.
4. Sufficient attention and care for Vulnerable Building Users in ‘situations of risk’ – refer to Article 11 of the 2006 United Nations Convention on the Rights of Persons with Disabilities.
5. Safety of Firefighters & Rescue Teams – refer to Essential Requirement 2 of the European Union’s Construction Products Directive 89/106/EEC.

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In this Overhead Presentation …

• Clearly outlined is a Holistic Perspective of the much wider scope for Sustainable Fire Engineering in the Future … Fire Engineering which has an empirical and scientifically robust foundation … Fire Engineering which is not afraid to confront and absorb the lessons of the 9-11 WTC Incident (2001) in New York, or the 2008 Mumbai ‘Hive Attacks’ … Fire Engineering which discards its outrageously shameful disregard for People with Activity Limitations … Fire Engineering which understands Fire-Induced Progressive Collapse and Disproportionate Damage in Buildings and, most importantly, understands the difference between these two related structural concepts … Fire Engineering which is capable of full integration with the Mainstream Construction Sector ;
• Sustainable Human & Social Development is clearly defined, and the current widespread confusion about the far more limited concept of ‘Green’ is removed ;
• The UNESCO WFEO/FMOI Model Code of Ethics, updated by CJ Walsh in 2011, is proposed as a suitable and very necessary template for the Institution of Fire Engineers (IFE) ;
• As Sustainable Design Solutions are appropriate to Local Geography, Culture, Climate (and Climate Change), Economy, Social Need, Language/Dialect, etc … it is strongly recommended that the IFE should develop Global Regional Guidance Documents on Sustainable Fire Engineering, i.e. separate documents for Africa, Asia, Europe, South America, etc ;
• Finally … this Presentation initiates a fresh and entirely new dialogue within the International Fire Science and Engineering Community.

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What are your views and comments ?

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END

Tags: 2011 IFE Cardiff Overhead Presentation, 2011 IFE International Fire Conference and AGM in Cardiff Wales, a Fire Engineering Code of Ethics is essential, Accessibility-for-All, Accessible Fire Engineering, Adaptation to Climate Change and Severe Weather Events, always bearing in mind that the minimum Building Life Cycle for a Sustainable Building is 100 years, Area of Rescue Assistance in a Building, Article 11 of the 2006 United Nations Convention on the Rights of Persons with Disabilities, Australia, Built Environment, Canada, Cardiff the Capital City of Wales, CJ Walsh: "Sustainable Fire Engineering IS THE FUTURE !", Clearly outlined is a Holistic Perspective of the much wider scope for Sustainable Fire Engineering in the Future, Client Organizations, Climate Change Adaptation, Essential Requirement 2 of the European Union's Construction Products Directive 89/106/EEC, Ethically Based Sustainable Fire Engineering, EU, european union, Fire Engineering Design, Fire Engineering which discards its outrageously shameful disregard for People with Activity Limitations, Fire Engineering which has an empirical and scientifically robust foundation, Fire Engineering which is capable of full integration with the Mainstream Construction Sector, Fire Engineering which is not afraid to confront and absorb the lessons of the 9-11 WTC Incident (2001) in New York or the 2008 Mumbai 'Hive Attacks', Fire Engineering which understands Fire-Induced Progressive Collapse and Disproportionate Damage in Buildings and - most importantly - understands the difference between these two related structural c, Fire Safety, fire-induced progressive collapse, FireOx International, Great Britain, Hong Kong (in China), human and social rights, human environment, in designing a building for fire and its immediate aftermath, In order to properly protect the interests of Society and our Clients/Client Organizations, initiated an important programme of activities during his 2010/2011 Term of Office on the theme of 'Sustainability & Fire Engineering', International Legal Instrument, Ireland, Irish Isles, it is necessary for the Fire Engineer to develop Project-Specific Fire Engineering Design Objectives, it is strongly recommended that the IFE should develop Global Regional Guidance Documents on Sustainable Fire Engineering, Malaysia, New Zealand, Nigeria, not less than a recurrence interval of 100 years should be used in design, People with Activity Limitations (2001 WHO ICF), Personnes à Performances Réduites (2001 WHO ICF), Resistance to Fire-Induced Progressive Building Collapse and Disproportionate Damage, Safety of Firefighters and Rescue Teams, Sufficient attention and care for Vulnerable Building Users in 'situations of risk', Sustainability Implementation, Sustainable Design Solutions are appropriate to Local Geography - Culture - Climate (and Climate Change) - Economy - Social Need - Language/Dialect, Sustainable Fire Engineering, Sustainable Fire Engineering is concerned with far more than compliance with Legislation, Sustainable Human & Social Development, Switzerland, Taiwan, Technical Control of Construction, the current widespread confusion about the far more limited concept of 'Green' is removed, the following issues which are relevant to Today's Human Environment, The Immediate Past President of the IFE Mr John Woodcock, the Institution of Fire Engineers (IFE) held its Annual General Meeting (AGM) followed by a very well attended 1½ Day International Fire Conference, The Netherlands, The New IFE President for 2011/2012 Mr. H.G. (Hao-Giang) Tay has stated that he will continue this work with enthusiasm, The UNESCO WFEO/FMOI Model Code of Ethics - updated by CJ Walsh in 2011 - is proposed as a suitable and very necessary template for the Institution of Fire Engineers (IFE), This brings me very neatly to the reason for my attendance at the Cardiff 'Gig', this Presentation initiates a fresh and entirely new dialogue within the International Fire Science and Engineering Community, to effectively realize a Safe and Sustainable Built Environment in the 21st Century, Tremendous Damage was caused to the Local Environment in Buncefield ... but Our Planet can no longer suffer these Criminal Human Acts, United Nations Convention on the Rights of Persons with Disabilities, United States of America, What are your views and comments ?, which must never be confused with the minimal Fire Safety Objectives mandated in Building and Fire Regulations and Codes

Fantasy Climate Change Policies, Landfill Gases & Water ?!?

2011-07-15:  The recent failure by European Union Environment Ministers to increase, unconditionally, the EU 2020 GHG Emission Reduction Target from 20% below 1990 levels to 30% … and the even more recent vote in the European Parliament against such an unconditional increase … leaves a stench in the nostrils.  Something stinks … and it’s the EU’s Climate Change Policy.  Too many alterations to the European Lifestyle … too many sacrifices … are required to effectively implement a ‘real’ climate change policy !

Taken as a whole … this is also a reliable indicator with regard to what is not happening in a strongly related policy area … the implementation of EU Sustainability Policy.

.

The next BIG United Nations International Climate Change Conference in 2011 – COP 17 – will take place from 28 November to 9 December, 2011 … in Durban, South Africa.  Let’s not get our hopes up for the long-awaited, very necessary and urgent Global, Legally Binding Consensus Agreement on Climate Change Mitigation to be finalized there … but let’s not be too negative either !

And how are the UNFCCC Annex I Countries doing so far ?   For an answer, please follow the link below to the United Nations Framework Convention on Climate Change (UNFCCC) WebSite …

Official UNFCCC Map – All Annex I Countries

I wrote ‘an answer’ … as this is not ‘the answer’ … because the Climate Change Numbers produced by each country are not yet sufficiently accurate, precise and reliable.  In fact, there is so much massaging of numbers that it might be better just to imagine this whole process as the Climate Change Red Light District !

BUT … we do know enough to be able to identify the worst offenders:

• 34 – IRELAND !
• 35 – Iceland
• 36 – Greece
• 37 – Portugal
• 38 – New Zealand
• 39 – Spain
• 40 – Canada
• 41 – Australia
• 42 – Malta
• 43 – Turkey

.

Looking back to when the Climate Change ‘Train’ began to come off the rails … the 2009 Copenhagen Accord was a political agreement between a small number of Heads of State, Heads of Government, Ministers, and Heads of Delegation from Brazil, South Africa, India and China (BASIC) and the USA … who attended the UNFCCC Climate Change Summit in December 2009.  Many countries have made voluntary submissions, i.e. not legally binding, to Appendices I and II of the Accord.

A general overview of the submissions made by the Developed Economies, however, reveals the following about the emissions targets being undertaken …

     -   they are highly conditional on the performance of other countries ;

     -   they are very disappointing … being far below what is required to cap the planetary temperature rise at 1.5 degrees Celsius ;   and

     -   there is no consistent emission base year … varying, for example, from 1990, 1992, 2000 to 2005.

This is very far from being a signal of serious intent from these countries … and is not … in any way, shape or manner … an acceptance of historical responsibilities.  It would be reasonable, therefore, to surmise that the process of achieving a global, legally binding, consensus agreement on greenhouse gas (GHG) emission reduction targets will be long and difficult.  The Climate Change Mitigation Agenda is fraught with difficulty … and is going absolutely nowhere at present !

Some Conclusions about Copenhagen and Since:

1. The Danish Organizers were entirely responsible for the 2009 Climate Change Train Wreck !   And … this incompetent bungling continues to contaminate events since then.
2. All Sectors of Europe’s Social Environment must now take seriously, i.e. pro-actively engage with, the Climate Change Adaptation Agenda … and prepare for a planetary temperature rise of at least 3-4 degrees Celsius before the end of this century !!

. 

Meanwhile, at national level in Ireland … and further to my post, dated 23 February 2011 … the Environmental Protection Agency (EPA) issued the following Press Release on 4 July 2011 …

‘ Kerdiffstown Landfill Remediation Project – Community Update Number No. 4

Gas flares at the Kerdiffstown Landfill are now installed and fully operational.  The flares burn off odorous gas that is collected by gas wells in two areas at the site – the lined landfill cell, and the North-West corner.

The lined landfill cell has now been fully covered with a heavy plastic membrane that will prevent gas escaping into the air.  This membrane will also stop rainwater getting into the waste and creating ‘leachate’ – the residual liquid that seeps through waste after rainfall.

These temporary gas control measures should result in a reduction in odour coming from the site.  Odour will continue to be encountered on occasion until the full remediation is completed and, in particular, there is a risk of odour during work phases where wastes will be disturbed.

The next major remedial works to occur on site will be the demolition of a number of unsafe buildings. The buildings are scheduled to be demolished in August, and the EPA will communicate the specific dates before the works commence.

On Friday, 1 July 2011, the EPA welcomed a number of TDs, councillors, council officials and members of the local community to the site for a briefing, and tour of the site works done to date.  The EPA would like to thank deputies Emmet Stagg, Anthony Lawlor, and Catherine Murphy, and Councillors Anne Breen, Emer McDaid, and Ger Dunne, for attending.

The EPA then met with members of the Local Community for the first Community Liaison Group meeting.  This group was formed to ensure that those people affected by the site can communicate directly with the people who will clean the site.  The Liaison Group includes EPA staff, Kildare County Council officials, members of CAN (Clean Air Naas), a representative from Kerdiffstown House, and local residents and business people.  The group took a tour of the site to review ongoing remedial works.

The EPA will continue to issue Community Updates as remedial works on the site take place.  For information about works at the site, go to … www.kerdiffstowncleanup.ie .’

.

Please read, again, that first paragraph of the Press Release above … and pinch yourself !

Ireland’s EPA has an onerous legal responsibility with regard to the development and implementation of this country’s National Climate Change Policy.  Furthermore … the EPA, on its own WebSite ( http://www.epa.ie/ ) states the following …

‘ The Environmental Protection Agency (EPA) aims to be a leader in the climate change debate in Ireland, and to be the first port of call for information on climate change.  We hope that the information we provide on these WebPages will keep you informed on the latest news, research and events in the climate change area, not only in Ireland but internationally.’

.

I ask: “Why are those Landfill Gases at Kerdiffstown being burned off ???”

Because Ireland’s National Climate Change Policy is a ‘paper’ policy … an ‘Alice in Wonderland’ policy … a policy not intended for ‘real’ implementation.  Surely we have a right to expect that, within the same national organization … somebody, somewhere … is able to think laterally ?

Climate Change Time is running out … and there is an immediate and desperate need for simple, direct and honest talk, consultation, awareness raising, training and education … across all sectors of our Social Environment !

. 

At European level … an example, to follow below, of the continuing weak and feeble Climate Change Language still being used by EU Institutions and Official Organizations … where individual employees, of all ranks, are more fearful of offending national and/or EU politicians than they are in doing their jobs properly and protecting EU Citizens and the Environment …

A recently published European Environment Agency (EEA) Technical Report 7: ‘Safe Water & Healthy Water Services in a Changing Environment’ … summarises existing knowledge of Climate Change Impacts on water services and health; the nature and effectiveness of the policy responses; and the coverage and gaps in existing assessments of these themes.

To download the Full Technical Report, go to the EEA’s WebSite … http://www.eea.europa.eu/ .

.

‘ Climate Change, Water & Health

• Millennium Development Goal 7 (MDG7) is to halve the proportion of the global population without sustainable access to safe drinking water and basic sanitation by 2015.  A World Health Organization (WHO) assessment in 2010 finds that access to improved water sources, sanitation and wastewater treatment has increased over the past two decades.  In many countries in the Eastern European Region, however, progress is slow.  More than 50% of the rural population in ten countries have no access to improved water, giving rise to important health inequalities.

• It is important to understand how Climate Change and Extreme Weather Events will affect the achievement of MDG7.  Drinking water supplies and sanitation systems will have to be made resilient to Climate Change, and drinking water and sanitation must be fully incorporated into integrated water resource management.

• Climate Change is projected to cause major changes in yearly and seasonal precipitation and water flow, flooding and coastal erosion risks, water quality, and the distribution of species and ecosystems.

• Climate Change will impact all areas of water services – the quality and availability of water sources, infrastructure, and the type of treatment needed to meet quality standards.  We will also see more frequent and severe droughts, flooding and weather events.

• Countries of Eastern Europe, the Caucasus and Central Asia face the greatest threats to safe water.  The infrastructure in many towns and rural areas is in poor condition, and water provision is erratic and of unsatisfactory quality.

• Heavy rainfall events may also lead to flooding, especially in urban areas, and this can have serious impacts on the performance and efficiency of water supply and wastewater treatment systems, which may potentially lead to health risks.  Waterborne diseases arise predominantly from contamination of water supplies after heavy rainfall and flooding.

• Low river flows and increased temperatures during droughts reduce dilution of wastewater effluent, and drinking water quality could be compromised, increasing the need for extra treatment of both effluent and water supplies.

Water Management Policies & Extreme Weather Events

• Water management policies at European and EU Levels are being made increasingly adaptable to Climate Change, which should help safeguard public health and ecosystem services in the future.

• There are numerous guidelines for the design of water and human health policies across Europe (e.g. WHO Guidelines on drinking water quality, Protocol on Water and Health, and draft guidance on water supply and sanitation in extreme weather).  Recently, such Guidance has focused on how policy design and implementation might be affected by and adapted to Climate Change Events.

• The WHO Vision 2030 Study assesses how and where Climate Change will affect drinking water and sanitation in the medium term, and what can be done to maximise the resilience of drinking water and sanitation systems.

• Several existing EU Policies address water management issues (the Urban Wastewater Treatment Directive, the Water Framework Directive, Floods Directive and the EU Water Scarcity and Droughts Strategy) and others deal more directly with potential water-related impacts on human health (e.g. the Drinking Water Directive, and Bathing Water Directive).

• There is a clear recognition that Climate Change creates a need for coherent, sustainable, cross-sectoral policy and regulation; sharing of available tools; facilitating mechanisms for partnerships and financing; and readiness to optimise across sectors during implementation.

• The water utility sector faces a unique set of challenges.  A primary challenge will be enhancing its capacity to cope with Climate Change Impacts and Other Human Pressures on water systems, while fostering greater resiliency to extreme hydrological events.

• With more frequent higher-intensity storms projected, utilities face the need to update infrastructure design practices.  This necessitates investments – not necessarily only in larger structures but also smarter (using better process control technologies) or local measures on storm water run-off.

Assessment Knowledge Base

• At international, national and local levels … much information is produced for assessments of the state of water and related health impacts.  Overall, both the current international and national water and health assessments have limited focus on extreme weather events and their effects on water services.

• In national assessments and programmes, countries appear to be aware of the adverse consequences of Climate Change on water and health.  However, sometimes assessments appear to be based on ‘expert knowledge’, largely qualitative in scope, and not going further than identifying likely scenarios.  The evidence‑base is lacking to make reliable estimates of the health effects of Climate Change resulting from impacts on water resources.

• Much effort is now focused on the impact of Climate Change on water and the environment, including health-related impacts.  Many international and European organisations have mapped out future Climate Change Impacts on water-related issues, identifying vulnerable groups and vulnerable sub-regions.

• The vast majority of the assessments of drought and water scarcity have focused on the impact of water scarcity, water use by sectors and strategies for meeting demand.  Very little consideration has been given to the health effects or consequences of future extreme weather events.

• The health effects of flooding do not feature significantly in national assessments.  The main focus is identifying regions most at risk of flooding and preparing plans for responding and mitigating the main consequences.

• Sufficient public health competences exist to cope with the health effects of Climate Change.  However, no (comprehensive) assessment has been undertaken to predict the severity or extent of future health risks related to the impact of Climate Change on water services.

• Irrespective of an assessment of the disease burden, actions being taken on the wider scale to respond to water scarcity, drought and flooding will help to reduce the health effects associated with Climate Change and water.’

.

If you were a Key Decision-Maker … would this language spur you into action … or make you yawn, and put you to sleep ???

.

.

END

Tags: 2009 Copenhagen Accord, A general overview of the submissions made by the Developed Economies, a political agreement between a small number of Heads of State - Heads of Government - Ministers - Heads of Delegation from Brazil - South Africa - India - China (BASIC) and the USA, All Sectors of Europe's Social Environment must now take seriously the Climate Change Adaptation Agenda, Assessment Knowledge Base, Australia, Because Ireland's National Climate Change Policy is a 'paper' policy ... an 'Alice in Wonderland' policy ... a policy not intended for 'real' implementation, Built Environment, BUT ... we do know enough to be able to identify the worst offenders, Canada, Climate Change Adaptation, Climate Change and Extreme Weather Events will affect the achievement of MDG7, Climate Change is projected to cause major changes in yearly and seasonal precipitation and water flow, Climate Change Time is running out, Climate Change Water and Health, Climate Change will impact all areas of water services, Countries of Eastern Europe - the Caucasus - Central Asia face the greatest threats to safe water, drinking water and sanitation must be fully incorporated into integrated water resource management, Drinking water supplies and sanitation systems will have to be made resilient to Climate Change, Environmental Protection Agency (EPA) issued the following Press Release on 4 July 2011, EU, EU's Climate Change Policy, European Environment Agency (EEA) Technical Report 7: 'Safe Water & Healthy Water Services in a Changing Environment', European Parliament, european union, European Union Environment Ministers, Fantasy Climate Change Policies Landfill Gases and Water, Gas flares at the Kerdiffstown Landfill are now installed and fully operational, Greece, human and social rights, I ask: "Why are those Landfill Gases at Kerdiffstown being burned off ???", Iceland, If you were a Key Decision-Maker ... would this language spur you into action ... or make you yawn and put you to sleep, Ireland, Ireland's EPA has an onerous legal responsibility with regard to the development and implementation of this country's National Climate Change Policy, is not ... in any way shape or manner ... an acceptance of historical responsibilities, Kerdiffstown Landfill Remediation Project - Community Update Number No. 4, Looking back to when the Climate Change 'Train' began to come off the rails, Malta, Meanwhile at national level in Ireland ..., Millennium Development Goal 7 (MDG7), New Zealand, Official UNFCCC Map - All Annex I Countries, Portugal, prepare for a planetary temperature rise of at least 3-4 degrees Celsius before the end of this century, pro-actively engage with, Social Environment, Some Conclusions about Copenhagen and Since, Spain, summarises existing knowledge of Climate Change Impacts on water services and health, Surely we have a right to expect that within the same national organization ... somebody somewhere ... is able to think laterally, Sustainability Implementation, The Climate Change Mitigation Agenda is fraught with difficulty ... and is going absolutely nowhere at present, the Climate Change Numbers produced by each country are not yet sufficiently accurate precise and reliable, the continuing weak and feeble Climate Change Language still being used by EU Institutions and Official Organizations, the coverage and gaps in existing assessments of these themes, The Danish Organizers were entirely responsible for the 2009 Climate Change Train Wreck, The flares burn off odorous gas that is collected by gas wells in two areas at the site, the implementation of EU Sustainability Policy, the long-awaited very necessary and urgent Global Legally Binding Consensus Agreement on Climate Change Mitigation, the nature and effectiveness of the policy responses, The next BIG United Nations International Climate Change Conference in 2011 - COP 17, the quality and availability of water sources - infrastructure - the type of treatment needed to meet quality standards, The water utility sector faces a unique set of challenges, The WHO Vision 2030 Study assesses how and where Climate Change will affect drinking water and sanitation in the medium term, There is a clear recognition that Climate Change creates a need for coherent sustainable cross-sectoral policy and regulation, there is no consistent emission base year ... varying from 1990 - 1992 - 2000 - 2005, there is so much massaging of numbers that it might be better just to imagine this whole process as the Climate Change Red Light District, they are highly conditional on the performance of other countries, they are very disappointing ... being far below what is required to cap the planetary temperature rise at 1.5 degrees Celsius, this incompetent bungling continues to contaminate events since then, this is also a reliable indicator with regard to what is not happening in a strongly related policy area, This is very far from being a signal of serious intent from these countries, to halve the proportion of the global population without sustainable access to safe drinking water and basic sanitation by 2015, to increase - unconditionally - the EU 2020 GHG Emission Reduction Target from 20% below 1990 levels to 30%, Too many alterations to the European Lifestyle, too many sacrifices ... are required to effectively implement a 'real' climate change policy, Turkey, UNFCCC Annex I Countries, United Nations Framework Convention on Climate Change (UNFCCC) WebSite, United States of America, Water Management Policies and Extreme Weather Events, where individual employees of all ranks are more fearful of offending national and/or EU politicians than they are in doing their jobs properly and protecting EU Citizens and the Environment

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.

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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.

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END

Tags: 'Misjudging Risk: Causes of the Systemic Banking Crisis in Ireland', 2011 Nyberg Report - 5.1 Findings - General, 2011 Nyberg Report - 5.2 Findings - Banks, 2011 Nyberg Report - 5.3 Findings - Authorities, 2011 Nyberg Report - 5.4 Why Did It All Come Together ?, 2011 Nyberg Report - 5.5 Specific Irish Features, 2011 Nyberg Report - 5.6 Lessons to be Learned from the Irish Experience, 2011 Nyberg Report - Chapter 5 - Findings and Final Considerations, Anglo Irish Bank (Anglo) was a monoline bank providing rapid but not cheap financing to a number of long-standing customers, as they engage in an elitist game of musical chairs around the boardrooms and senior management levels of our national institutions, Bank Business Models and Strategies in Ireland, Bank Funding Liquidity and Capital in Ireland, Becoming a Mature Independent National State must sometimes be a painful experience, Exit from the Banking Crisis and Restore the Banking System to Health, Further Improve Competitiveness in Order to Support Export-led Growth, In Ireland a big deal has been made of losing our National Economic Sovereignty, Ireland, Ireland's Corrupt and Dysfunctional National Economic Governance, Ireland's National Economic Governance ?, It has been a hectic few weeks here in Ireland ..., It will take us a month of Sundays to recover, Nobody saw anything ... nobody heard anything ... nobody knew anything, OECD Economic Surveys - Ireland (October 2011) - OVERVIEW SUMMARY, on 14 October 2011 in Dublin ... the Organization for Economic Co-Operation and Development (OECD) presented its latest Economic Survey of Ireland, on 19 April 2011 ... the Report of the Commission of Investigation into the Banking Sector in Ireland was published, On boards there appears to often have existed a collegiate and consensual style with little serious challenge or debate, On joining the EuroZone Irish banks gained increased access to wholesale funding at a relatively low cost, Persevere on the Path of Fiscal Consolidation, Prevent High Unemployment from Becoming Structural, Regulation as Seen by Banks in Ireland, Risk management structures proved largely ineffective in prudently managing and controlling rapid growth, Since 2008 the government has carried out a very sizeable fiscal consolidation, Social and Economic Environments in Ireland ?, successful visits to our country by Queen Elizabeth II of England and President Barack O'Bama(!) of the United States of America, the Big Picture of a Completely Corrupt & Dysfunctional System of Irish Economic Governance, The Central Bank in Ireland, The Department of Finance (DoF) in Ireland, the Economic Catastrophe which befell Ireland in the period leading up to and during 2008, the Economic Environment is not the same as the Social Environment, The Financial Regulator in Ireland, The following extract from the 2011 Nyberg Report, the Guilty the Incompetent and the Inept, The intention of the Irish Government at the time that these Investigations were established was to obscure ... as much as possible, 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, the Leinster Rugby Team winning the Heineken Cup in Cardiff, The main reason was the unhindered expansion of the property bubble financed by the banks using wholesale market funding, the Munster Rugby Team then beating Leinster a week later to win the Magner's League Final in Limerick, 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, The Social Environment shapes binds together and directs the future development of the Built and Virtual Environments, This document was prepared by Mr. Peter Nyberg a Finnish Economist ... and sole member of the Commission, this is just one report ... in a series of reports purporting to thoroughly examine separate aspects, We - the Citizens of Ireland - are therefore not in a position to clearly identify these 'mothers', will give you a small and very mild flavour of what was happening during the Celtic Tiger Years, within a still developing system of shared sovereignty balanced across all aspects of European Society

2011 Dublin ‘Girón 50′ Victory Symposium – Final Declaration !

2011-04-23:  Never do I cease to be amazed at the number of highly vocal ‘experts’ who pontificate about the small Caribbean island state of Cuba … which has a population of approximately 11 million people, with about 2.5 million of those living in the capital city of Havana … and not once have these ‘experts’ set foot on this beautiful island.  What a pity !

A certain fascination with the 1959 Cuban Revolution and its Leaders … and a large dose of curiosity about the countryside and its people … were the principal drivers behind an extensive Family Tour in April 2007 … before Fidel Castro departed the scene.  At the time, he was seriously ill.

Straight away, therefore, let me clarify that I do not consider the Tourist Resort of Varadero to be an accurate representation of everyday life and living in Cuba.  And I mean that in the worst possible way !   Similarly, the illegally occupied U.S. Military Base at Guantánamo Bay must be excluded as a valid island experience … the annexation of the bay area remains, to this day, an international act of piracy – see the  1901 Platt Amendment  and later Treaties with Cuba procured by the threat or use of force.

Getting back to those ‘experts’ … sometimes, they might be rabid, Older Generation Cuban Exiles now living in Miami (USA) … the privileged island classes of the 1950′s … who either left hurriedly or were booted out after the success of the Castro Revolution.  At other times, the ‘experts’ might be Criminal Ex-Members of Dictator Fulgencio Batista’s Military and Police Forces who are still working for the U.S. Central Intelligence Agency.  For some unknown reason, however, both groups continue to hold the United States Political System – at Florida State and Federal Levels – by the balls !   Sad, but true !!

In its early days, Castro’s Revolutionary Government abolished racial discrimination, reduced rents and the cost of electricity, nationalized American and British commercial firms, and permanently ‘evicted’ the American Mafia.  The new government, however, was far from being firmly rooted, confident and stable … but all of that changed, utterly, after events in April 1961 …

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On Saturday last, 16 April 2011 … I attended a day long ‘Girón 50′ Symposium and Victory Celebration, which was held in Liberty Hall, Dublin.  This special occasion commemorated the 50th Anniversary of the Cuban Victory at the Bay of Pigs (Bahia de Cochinos) … scene of the ill-fated 1961 U.S. Inspired, Financed and Resourced Counter-Revolutionary Invasion of Cuba.

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The route taken by the 1961 U.S. Invasion Force was elaborate and circuitous …

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Playa Girón was one of the landing points in the 1961 U.S. Bay of Pigs (Bahia de Cochinos) Invasion …

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2011 Dublin ‘Girón 50′ Victory Symposium – Liberty Hall

FINAL DECLARATION

We, the participants in the ‘Girón 50′ Conference commemorating the 50th Anniversary of the Cuban Victory at the Bay of Pigs:

1.  Express our firm solidarity with the Cuban Revolution and Its People in their struggle for the defence of their independence, sovereignty and right to build a social and political system of their own choice, with no outside interference.

2.  Salute the process of comprehensive and popular debate in Cuban Society which led to the set of guidelines to be discussed and approved during the next few days by the 6th Congress of the Communist Party of Cuba, which is aimed at renewing and updating its economic policy in accordance with the current domestic, regional and international situation.

3.  Condemn the illegal and criminal U.S. Economic, Financial and Trade Blockade, which Cuba has suffered for over five decades and which continues to be a flagrant violation of the right of an entire nation to self-determination and the main obstacle to Cuba’s development.

4.  Call on the European Union (E.U.) to unconditionally rescind the 1996 E.U. Common Position 96/697/CFSP on Cuba, and to seriously engage in a process of normalization of relations with the island, based on mutual respect and non-interference in their internal affairs.

5.  Condemn the ongoing U.S. Sponsored Subversion and Terrorist Actions aimed at overthrowing the Cuban Revolution, and U.S. Double Standards in its War on Terror … once again illustrated by the recent acquittal of Luis Posada Carilles, self-confessed instigator of the Bombing of Cubana Airlines Flight CU-455, which killed all 73 people on board, as it travelled from Venezuela to Cuba, via Barbados, on 6 October 1976.

6.  Extend our support for the International Campaign of Freedom & Exoneration for the Miami Five – Gerardo Hernández, Antonio Guerrero, Ramón Labañino, René González and Fernando González – the Five Cubans illegally and unjustly imprisoned in the U.S. for fighting terrorism … and join the growing international call on President Obama, including that of Former U.S. President Jimmy Carter, to release them immediately.

7.  Call on the Irish Government to continue the development of Bilateral Relations with Cuba, and Ireland’s support for the lifting of the U.S. Blockade and the rescinding of the E.U. Common Position on Cuba.

8.  Commit ourselves to undertake the relevant Solidarity Actions in support of Cuba.

Liberty Hall, Dublin.

16 April 2011.

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AS WE approach Easter Sunday, 2011 … let us remember the Miami Five who have been unjustly incarcerated for much too long …

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AND … after the Bay of Pigs, Vietnam, many countries in Central & South America, Iraq and Afghanistan … let us ponder, at length, on the question of when, if ever, the United States of America will learn to join the International Community of Nations … as an equal !

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END

Tags: 1961 U.S. Inspired Financed and Resourced Counter-Revolutionary Invasion of Cuba, 2011 Dublin 'Girón 50' Victory Symposium - Final Declaration, 50th Anniversary of the Cuban Victory at the Bay of Pigs (Bahia de Cochinos), 6th Congress of the Communist Party of Cuba, A certain fascination with the 1959 Cuban Revolution and its Leaders, a large dose of curiosity about the countryside and its people, after the Bay of Pigs - Vietnam - many countries in Central and South America - Iraq - Afghanistan, all of that changed utterly after events in April 1961, before Fidel Castro departed the scene, both groups continue to hold the United States Political System by the balls, Built Environment, Call on the Irish Government to continue the development of Bilateral Relations with Cuba, Castro's Revolutionary Government abolished racial discrimination, Client Organizations, Commit ourselves to undertake the relevant Solidarity Actions in support of Cuba, Criminal Ex-Members of Dictator Fulgencio Batista's Military and Police Forces, Cuba, Cuba ... which has a population of approximately 11 million people, european union, Gerardo Hernández - Antonio Guerrero - Ramón Labañino - René González - Fernando González, human and social rights, human environment, I do not consider the Tourist Resort of Varadero to be an accurate representation of everyday life and living in Cuba, Ireland, Ireland's support for the lifting of the U.S. Blockade, let us remember the Miami Five who have been unjustly incarcerated for much too long, nationalized American and British commercial firms, not once have these 'experts' set foot on this beautiful island, our firm solidarity with the Cuban Revolution and Its People, our support for the International Campaign of Freedom & Exoneration for the Miami Five, permanently 'evicted' the American Mafia, Playa Girón was one of the landing points in the 1961 U.S. Bay of Pigs (Bahia de Cochinos) Invasion, Politics, rabid Older Generation Cuban Exiles now living in Miami (USA), reduced rents and the cost of electricity, see the 1901 Platt Amendment and later Treaties with Cuba procured by the threat or use of force, Social Environment, still working for the U.S. Central Intelligence Agency, the annexation of the bay area remains an international act of piracy, the Bombing of Cubana Airlines Flight CU-455 which killed all 73 people on board, The First Defeat of Yankee Imperialism in Latin America, the illegal and criminal U.S. Economic Financial and Trade Blockade, the illegally occupied U.S. Military Base at Guantánamo Bay must be excluded as a valid island experience, The new government was far from being firmly rooted confident and stable, the number of highly vocal 'experts' who pontificate about the small Caribbean island state of Cuba, the ongoing U.S. Sponsored Subversion and Terrorist Actions aimed at overthrowing the Cuban Revolution, the principal drivers behind an extensive Family Tour in April 2007, the privileged island classes of the 1950's, the question of when the United States of America will learn to join the International Community of Nations ... as an equal, the recent acquittal of Luis Posada Carilles, The route taken by the 1961 U.S. Invasion Force was elaborate and circuitous, to unconditionally rescind the 1996 E.U. Common Position 96/697/CFSP on Cuba, U.S. Double Standards in its War on Terror, United States of America, who either left hurriedly or were booted out after the success of the Castro Revolution, with about 2.5 million of those living in the capital city of Havana

Osaka’s 2011 Cherry Blossom Walk in Post-Disaster Japan ?

2011-04-19:  This year’s Osaka Cherry Blossom Viewing & Festival Market is taking place right now … from 14 April until 20 April 2011 … at the Osaka Mint Bureau (Zoheikyoku) … the head office of Japan Mint … a governmental agency responsible for the supply of coins and medals, and the analysis, testing and certification of metals.

The 560 metre long Cherry Blossom Walk in Osaka is famous, throughout Japan, for its 352 Cherry (Sakura) Trees … comprising 128 Cherry Varieties.  It is open for public viewing during one week each year, usually in April, when the flowers are in full bloom.

In 2010, there were 602,000 visitors … and I was very fortunate to be one of those !

In 2011, the Themed Flowering Cherry is ‘IMOSE’ … so named, because it often bears two fruits from one flower.  The flowers are light and dark red in colour … with around 30 petals, which bloom in two stages.

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Before the recent Tōhoku Earthquake and Tsunami Disaster in Japan … I would have automatically selected photographs which focused on the Cherry Blossoms, and had few if any people in view.  Now, however, it is important to show ordinary Japanese people … people of all ages … enjoying a simple pleasure in life.  These are the very same people who were caught up in the tragedy, and continue to suffer horrendously.

Now is the time, after the world’s short attention span has moved on to the next natural or man-made disaster, to continue to keep these people in our thoughts.

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2011 Japanese Earthquake & Tsunami Appeal

I am a Member of the Ireland Japan Association (IJA).  If you wish to make a donation, please go directly to the IJA WebSite … http://www.ija.ie/ … and please, please give generously.  Thank you.

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END

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Sustainability in Action ?!? – The Edge’s Malibu Housing Project

2011-04-02:  While ‘sustainability’ may be a difficult concept to understand and implement … our collective consciousness of what is not sustainable … unsustainable … should be improving.  Does this, or that, intuitively ‘feel’ wrong ?   Please discuss.

This item came to my attention a few days ago, via an Architectural e-Newsletter from the ‘US of A’ … and it is a sad, sad reminder of the unsustainable construction frenzy which infected so many people in Ireland during the Celtic Tiger Years.

The Edge is one of our own … we delight in his success, and we are proud of him !

At the beginning of a slick and convincing promotional video, the Proposed Coastal Housing Development by The Edge (David Evans) and his wife Morleigh Steinberg, is described as follows …

” Leaves in the Wind is an innovative five-home green building and organic design project in Malibu, California.  Each home is actively seeking LEED Gold Certification from the U.S. Green Building Council.

All five terrain-appropriate, environmentally sustainable homes will be built on just over 1 acre of the 156-acre site, leaving most of the land untouched and in its natural state.”

A vague ‘artistic impression’ of each of the 5 Houses, available to download from the Project WebSite, shows that the designs are far from being earth-shatteringly innovative … and, in the case of at least 4 of the Houses, they will break the skyline at the top of the hills …

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David (aka The Edge) … some Questions and Comments …

1. A building which breaks a hilltop skyline has an enormously adverse visual impact.  Just visit the Bodrum Peninsula, in the south-west of Turkey, to see exactly what I am talking about.  Please move the houses in Malibu.  They are not ‘terrain-appropriate’.  Don’t destroy the visual enjoyment of the landscape for everyone else in the local community !
2. Yes … there are 5 Sites available for constructing 5 Houses.  BUT … do you really have a desperate urge to build all 5 ?   Why not just 1 … or 2 at the most … and find a ‘sustainable’ use, or uses, for the rest of the landscape ??   Are you familiar with ‘sustainable’ management ?   Would you like to do something to slow down the rate of, and perhaps even reverse, biodiversity loss in Malibu ?   If you have not done so already … would you like to consult, meaningfully, with members of the local community about your ideas … even at this advanced stage ?
3. Have you fully considered the large range of adverse environmental impacts during the long, difficult process of construction ?
4. Finally (for now) … I regret very much that you have been an innocent victim of Ubiquitous American Greenwash Marketing … with profound apologies to Canada, Mexico and the rest of Central and South America !   The U.S. Green Building Council’s LEED (Leadership in Energy and Environmental Design) Building Rating System is only concerned with certain environmental aspects of Sustainable Human & Social Development.  There are many other aspects to sustainability which are equally, if not more, important.  LEED is not a Sustainable Building Rating System.  And the Green Building Council, itself, knows this !   Please do some proper research !   And PLEASE … do this before the ‘real’ design process commences … and definitely, before any work starts on site !!

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