Building Energy Rating
BER Certificates & ‘Big Brother’ – 1984 Style ? (V)
‘Big Brother’ has arrived on our doorsteps … not in the style of today’s reality television … but in the George Orwell 1984 style of a generation ago … when 1984 used to be far into the distant future.
I wasn’t quite sure, but I thought that some readers … avid followers of Ireland’s BER Soap Opera … might be interested in the contents of a certain Important Notice Regarding BER Certificates (on official headed notepaper) … with the name of Mr. Steven Manek MIAVI, Partner, Douglas Newman Good (estate agents) at the bottom of the page … and dated March 2009 … which was circulated to DNG’s client vendors …
” We have now been advised by the Irish Auctioneers and Valuers Institute (IAVI) to contact all our vendor clients and advise them that an officer from one of the local authorities has started visiting estate agents’ offices in the greater Dublin area to inspect BER certificates for properties currently for sale/rent.
The IAVI have further advised us that if a certificate is not available the inspector is currently allowing a short grace period for provision of a certificate (even though there is no legal reason for them to do so). If a certificate is not available within that time frame there is a risk of prosecution thereafter as it is a legal requirement to provide a BER certificate. The maximum fine for a vendor under the legislation is €5,000.
In view of this we wish to formally notify you of your legal obligations and recommend that you obtain a BER certificate for your property as soon as possible.
The energy rating of a property must be carried out by a trained and registered SEI Building Energy Rating Assessor (BER Assessor). We have a panel of assessors that can undertake this certification for you and should you wish us to handle this for you please do not hesitate to contact me.”
Like too many other people … Steven does not seem to have taken the time to read the actual legislation. Or, maybe he has … which is worse … whatever !
The clear intention of this nasty piece of DNG propaganda, however, is to scare the living daylights out of their own client vendors … and to drive them, like lost little sheep into the long spindly arms of their own in-house BER Assessors.
Hold onto your liathróidí folks !
BER Certificates & Necessary Sectoral Infrastructure (IV)
The Construction Sector Comedy of Errors continues without intermission …
On Tuesday last, 2009-03-10, I attended a Conference in Dublin Castle: ‘Energy Efficiency in Historic(al) Buildings’, organized by the Department of the Environment, Heritage & Local Government (DEHLG) and the Irish Georgian Society. Boys and girls … we are in trouble … flat, uninspiring presentations from our beloved DEHLG policy makers. Missing … any wider context of required energy efficiency targets across the whole of the built environment … or views and solutions from anywhere else beyond our two little islands (Ireland & GB) on the periphery of Europe. The approach taken to this important subject was “let’s just jump in, and see what we can do”. What a day !
[Note: Thanks also to the DEHLG ... Ireland still has no National Climate Change Adaptation Policy.]
That same morning, on Tuesday, an Opinion Piece: ‘Research Hub Benefits All’ appeared in The Irish Times (page 13), written by no other than Mr. Kieran McGowan, Chairperson of CRH. He was full of suggestions about research in Ireland, and was most happy to support the proposed research alliance between University College Dublin (UCD) and Trinity College Dublin (TCD). However, a quick visit to the CRH Holding Company WebSite is both relevant and informative. There, you will learn that the Company operates in 35 countries, employing approximately 93,500 people. Entering the key words/phrases … ‘research’, ‘construction research’, and even ‘building research’ … into the site search engine yields nothing of value … that’s right … nichts, nada, niente, zilch, zero ! With all the window dressing about Corporate Social Responsibility (CSR), etc, etc … the principal ‘value’ in CRH still remains short term ‘shareholder value’. If it looks interesting, gobble it up. Why waste money on a Research Division ? … which should be located in Ireland !
Yesterday, 2009-03-13, another Article appeared in The Irish Times (bottom of page 5): ‘Ireland Closer to Kyoto Emissions Target Due to Economic Slump’, by Mr. Harry McGee, IT Political Staff (?). The Environmental Protection Agency (EPA) Press Release which generated this newspaper article was released on Wednesday, 2009-03-12, at 17.59 hrs. in the evening.
The 19-Page EPA Report: ‘Ireland’s Greenhouse Gas Emission Projections 2008-2020′ was issued on the same day as the newspaper article – 2009-03-13. Excellent media management !
These three different texts fail to examine, or even discuss, the following issues …
- How many € Millions and € Millions belonging to the Irish Tax Payer are being spent, and will be spent into the far future, on buying this country out of trouble … because of the abject failure to meet our responsibilities under Kyoto I (up to 2012), and the Real EU 2020 Target of -30% GHG Emissions on 1990 levels (assuming there will be an agreement in Copenhagen, next December, on a Post-2012 Kyoto II Instrument). This has always been the EU Target. See Paragraph 31, German Presidency Conclusions of the Brussels European Council (8 & 9th March 2007).
- Having seen the numbers and range of assumptions which underpin the EPA’s GHG Emission Projections up to 2020 … how Reliable are those projections ? Where are the critical Statements of Uncertainty ?
- Who are the Individuals who sat on their fat, over-paid asses throughout the last 10-15-20 years, and allowed this country to fall into such a haphazard state ? Would any of these individuals be the same people who are now preaching sermons on ‘responsible’ GHG Emission Compliance … and still foisting upon us Voluntary Codes of Practice and Compliance Schemes, Ineffectual National Marketing Campaigns, Feather Light Regulation, and Press Releases which obscure what is really happening ?
Do you see any parallels with current events in the Irish Financial Sector ?
- Can the Irish Construction Sector be expected to meet any Real Performance Targets (e.g. Proper Building Energy Rating Labelling, Meaningful GHG Emission Reductions, Serious Energy Efficiency Improvements, whatever … ) – as distinct from Theoretical Performance on paper – without a Very Necessary Sectoral Infrastructure capable of shaping suitable responses to those targets, and ensuring that they are implemented ?
As already discussed in an earlier Post … a Complete Cultural Shift in the Irish Construction Sector is essential. So, let me give you a small flavour of what we need to do …
1. Construction Data & Statistics:
Ireland does not currently possess a comprehensive National Construction Database. No reliable statistics can be presented with regard to building or construction-related performance in 1990, or 2005. No coherent projections, therefore, can be made for the years 2010, 2012, 2020 or 2050 … under any futures scenario.
The Central Statistics Office (CSO) gathers construction-related Economic Data. Energy Ireland (SEI) Databases are not reliable.
Construction is not identified as a separate Sector, by either the Environmental Protection Agency (Ireland) or the European Environment Agency (Denmark), in European Greenhouse Gas Emission (GHG) Databases.
2. A Concerted Programme of Infrastructure Restoration:
- Re-establish and adequately resource an Independent National Institute for Spatial Planning & Construction Research (formerly known as An Foras Forbartha) in Ireland, having joint responsibility with the CSO for maintaining a reliable National Construction Database.
Construction Research & Innovation must be given a high national priority !
The National Institute must establish close working relationships with the relevant European Union Institutions, particularly EuroStat in Luxembourg.
[By 'independent' ... I mean at a long, long, long arm's distance away from the Department of the Environment, Heritage & Local Government (DEHLG).]
- Re-establish and adequately resource an Independent and Fully Accredited National Construction Testing & Development Complex.
- Re-Format, Revise & Horizontally Integrate the National Building Regulations.
The existing format is both limited and seriously flawed. For discussion in a later Post.
- Adequately resource the Irish National Accreditation Board (NAB), and closely monitor the quality of its work.
- Adequately resource the National Standards Authority of Ireland (NSAI) and ensure that Ireland participates vigorously in the European Standards Organizations and ISO (International Standards Organization).
- Adequately resource an Independent Irish Agrément Board (IAB), and closely monitor the quality of its work.
[By 'independent' ... I mean at a long arm's distance away from the National Standards Authority of Ireland (NSAI). These two organizations were supposed to have been separated a few years ago anyway.]
- Adequately resource awareness raising and Institutional Capacity building for Sustainability and Climate Change Adaptation in the Department of the Environment, Heritage & Local Government (DEHLG), Energy Ireland (SEI) and the Construction Industry Federation (CIF).
- Adequately resource awareness raising, Re-Training and Re-Education for Sustainability and Climate Change Adaptation at all levels in the rest of the Construction Sector, including All (Professional) Design Disciplines and All Construction Organizations.
3. Initial Construction Quality:
Post-completion repairs and/or system retrofitting always involve compromises, are costly and are rarely anywhere near being 100% effective. Ensure Proper Initial Construction Performance through robust inspection of buildings during construction … checking that all relevant legislation has been complied with and that construction products have been approved, i.e. properly shown to be ‘fit for their intended use (in the location of use)’, etc.
- Adequately resource, with Staff (e.g. building controllers, inspectors, administrative, legal), Monitoring Equipment (e.g. sound meters, long wave infra-red cameras, etc.) and Technical Support (e.g. training, library facilities, access to research) … all Building Control Authorities in the country.
Introduce a fully Integrated (including Part B of the Building Regulations) and Mandatory Inspection Scheme on all Construction Projects, at the following Construction Stages …
Foundations ;
Drainage ;
Ground Floor Construction ;
Super-Structure (above Radon Resisting Membrane) … inspections to take place at a level no higher than first floor ;
Roof.
Such an Inspection Scheme must operate uniformly across the country. Piecemeal variations and maverick procedures operated by National Authorities Having Jurisdiction (AHJ’s) or Individual Local Authorities cannot any longer be tolerated.
4. Consumer Protection:
- Establish an Independent and Comprehensive National Building Insurance Scheme.
Self-Regulation by the Architectural and Legal Professions offers merely the ‘appearance’ of protection to the Irish Consumer.
The current system of Royal Institute of the Architects of Ireland (RIAI) / Law Society ‘Opinions on Compliance with Building Regulations’ is inadequate … and offers no protection to the Irish Consumer. The phrase ‘substantial compliance’ is much misunderstood and widely abused.
- Introduce and adequately resource the discipline of Independent Technical Controller. He/she must be independent from Construction-related Organizations, the Building Design and Legal Professions … Local Authorities … and any other National Authorities Having Jurisdiction (AHJ’s).
- Introduce a Mandatory Building Completion Certification System.
Before any Building can be occupied, a Certificate of Building Completion Performance, and an Accompanying Report, must be issued by an Independent Technical Controller. The System will include an independent evaluation of compliance with relevant building legislation and a thorough examination of ‘real’ construction performance.
Building Completion Documentation can be designed to include …
- a Fire Safety Certificate, which is issued only after adequate monitoring of the actual fire safety related construction ;
- a Disability Access Certificate, which is issued only after adequate monitoring of the actual access related construction ;
- a Building Energy Rating (BER) Label ;
- a Sustainability Impact Assessment (SIA) ;
- etc., etc.
[Many of the above ideas have been incorporated in the 2008 Institute of International & European Affairs (IIEA) Publication: 'The Climate Change Challenge', which presents a strategic overview of Irish Climate Change Policy.]
BER Certificates & Poor Indoor Air Quality (III)
Energy Labelling of Industrial Products is an essential means of raising consumer awareness about energy efficiency and conservation. I like being able to wander into an electrical shop anywhere in Ireland, Italy or Turkey, for example … and to compare the energy performance of different makes of washing machines, dishwashers or fridges … and even of apparently similar products in the different countries.
I can easily visualize these small industrial products being brought into a test laboratory, and then being put through their paces. It is a credible system.
This is NOT possible, however, with a building.
EU Directive 2002/91/EC of the European Parliament and of the Council, of 16 December 2002, on the Energy Performance of Buildings … is a short document of 7 Pages. Its Preamble takes up slightly more than the first 2 Pages, and there is a 1 Page Annex at the rear. Its language is clear and straightforward (see the example of Article 4 below).
[What I fail to understand is how and why the Irish National Legislation which implements the Directive ... Statutory Instrument No. 666 of 2006: European Communities (Energy Performance of Buildings) Regulations 2006 ... is so clumsy, awkward and full of flaws ... offering us yet another example of failed 'light-touch regulation'. It may also be unconstitutional.]
The EU Directive has something important to say about Indoor Air Quality …
Article 4 – Setting of Energy Performance Requirements
1. Member States shall take the necessary measures to ensure that minimum energy performance requirements for buildings are set, based on the methodology referred to in Article 3. When setting requirements, Member States may differentiate between new and existing buildings and different categories of buildings. These requirements shall take account of general indoor climate conditions, in order to avoid possible negative effects such as inadequate ventilation, as well as local conditions and the designated function and the age of the building.
[Quick flashback to a generation ago ... the panic, throughout Europe, to conserve energy in the late 1970s and early 1980s led to a dramatic reduction in rates and quantities of direct, natural ventilation to the habitable spaces of buildings. This, in turn, had an adverse impact on Indoor Air Quality, and led to a sharp rise in Asthma among building occupants.]
In Ireland, today, problems concerning Poor Indoor Air Quality continue to occur … typically during the Winter Heating Season. There is a natural tendency to keep windows closed and to seal permanent ventilation openings. Accidental indoor air seepage to the exterior is also being reduced in our newer building stock.
Poor Indoor Air Quality, an important factor in relation to building related ill-health (also known as ‘sick building syndrome’), can cause serious health impairments and severely restrict a person’s participation in everyday activities, e.g. work.
Symptoms and Signs may include:
- irritation of eyes, nose and throat ;
- respiratory infections and cough ;
- voice hoarseness and wheezing ;
- asthma ;
- dry mucous membrane and skin ;
- erythema (reddening or inflammation of the skin) ;
- lethargy ;
- mental fatigue and poor concentration ;
- headache ;
- stress ;
- hypersensitivity reactions, i.e. allergies ;
- nausea and dizziness ;
- cancers.
The following 2 Performance Indicators of Good Indoor Air Quality, developed with the aim of protecting human health, are recommended:
- Carbon Dioxide (CO2) concentrations in a building should not significantly exceed average external levels – typically within the range of 300 to 500 parts per million – but should at no time exceed 800 parts per million ;
- Radon Activity (including Rn-222, Rn-220, RnD) in a building should, on average, fall within the range of 10 to 40 Bq/m3 … but should at no time exceed 60 Bq/m3.
NOTES:
The concept of Protecting Human Health is altogether different from the concept of Assessing Risk to Safety.
In Ireland, testing for Radon Activity in buildings must take place during the Heating Season, i.e. the months of November through to March. What is the use of testing during July, for example, when windows will be wide open ? Who would even think of doing that ? I wonder.
Measurement Uncertainty of the standard Alpha Particle Etched-Track Detector distributed by the Radiological Protection Institute of Ireland (RPII) is as follows:
- under laboratory conditions: …………………… in the order of …… +/- 10%
- under tightly controlled site conditions: …. in the order of …… +/- 20%
- under typical conditions of use: …………….. well in excess of … +/- 30%
Unfortunately, until the RPII includes proper statements of Measurement Uncertainty in its Test Reports … our Organization cannot recommend RPII Radon Testing Services, and we will not accept RPII Test Reports as proper evidence of Radon Test Results.
BER Certificates, Energy Efficiency & Climate Change (II)
The World Business Council for Sustainable Development (WBCSD) has identified buildings as one of the five main users of energy where ‘megatrends’ are needed to transform global energy efficiency in the immediate short term, and so meet the daunting challenge of Climate Change Adaptation. They account for 40% of primary energy (primary energy includes the energy required to generate, transmit and distribute electricity, as well as energy directly consumed on site) in most developed countries, and consumption is rising.
… 2007 WBCSD Energy Efficiency in Buildings (EEB) Project
If you find that you are not responding emotionally to that … please leave your computer immediately and take a cold shower ! When you return, check out how far adrift Ireland is – even on paper – in meeting its legally binding 1997 Kyoto Protocol (UNFCCC) responsibilities. After 2012, the European Union’s 2020 Targets will be in a different league altogether.
Let there be do doubt, therefore, that over the next few years … nothing less than a complete cultural shift will be necessary throughout the European Construction Sector – and this very much includes Ireland – beginning with all research and design disciplines and extending right across to any person who works on a construction site or has any part to play in managing, maintaining or servicing a building.
Burden Sharing in the Built Environment
Separate Energy Efficiency Strategies will be required to vastly improve the energy performance of:
- existing buildings … onto which many energy efficiency measures can be successfully grafted … but they will not be cheap, and they will not be 100% effective ;
- buildings of historical, architectural or cultural importance … the integrity of which must be protected ; and
- new buildings, which must therefore carry the major burden.
In addition … if we fully value the Agricultural Industry in Ireland, the burden to be carried by New Buildings may have to be far heavier.
Suggested Building Energy Efficiency Targets in Ireland to 2020
From the Beginning of 2012, i.e. after an Essential Transition Period involving extensive re-education and up-skilling, accompanied by ‘attractive’ incentives …
- Require all New Buildings to achieve a Minimum Building Energy Rating (BER) of ‘A1′ … indicating a Primary Energy Consumption less than or equal to 25 kWh/m2/yr. And require 40% of Primary Energy Consumed to be, directly or indirectly, from Renewable Energy Sources ;
- Require all Existing Buildings to achieve a Minimum Building Energy Rating (BER) of ‘B1′ … indicating a Primary Energy Consumption less than or equal to 100 kWh/m2/yr. And require 15% of Primary Energy Consumed to be, directly or indirectly, from Renewable Energy Sources. Retain Incentive Measures to achieve better performance with regard to energy efficiency and/or renewable energies ;
- Require Buildings of Historical, Architectural or Cultural Importance to achieve a Minimum Building Energy Rating (BER) of ‘C1′ … indicating a Primary Energy Consumption less than or equal to 175 kWh/m2/yr. Retain Incentive Measures to achieve better energy efficiency performance. No legal requirements or incentives with regard to Renewable Energies should apply to Buildings of Historical, Architectural or Cultural Importance.
From the Beginning of 2015 …
- Require all New Buildings to be ‘Positive Energy Buildings’ (see below) ;
- Require all Existing Buildings to achieve a Minimum Building Energy Rating (BER) of ‘A2′ … indicating a Primary Energy Consumption less than or equal to 50 kWh/m2/yr. And require a Positive Energy Contribution of 25 kWh/m2/yr to be from renewable Energy Systems installed in the building ;
- Require Buildings of Historical, Architectural or Cultural Importance to achieve a Minimum Building Energy Rating (BER) of ‘B1′ … indicating a Primary Energy Consumption less than or equal to 100 kWh/m2/yr. Retain Incentive Measures to achieve better energy efficiency performance. No legal requirements or incentives with regard to Renewable Energies shall apply to Buildings of Historical, Architectural or Cultural Importance.
‘Effective’ Technical Control of Construction & Post-Occupation Buildings
Any proposed Building Energy Efficiency/Conservation and Renewable Energy Improvements must take place in a legal environment of stringent control during construction (by competent Local Authority Building Controllers and/or Independent Technical Controllers) and rigorous post-construction energy performance monitoring (using Long Wave Infra-Red Thermal Imagery, in conjunction with building roof and external wall Air Seepage Tests). Observation of post-occupation building energy performance will also be necessary. Introduce mandatory 5-Yearly Energy Surveying of Buildings.
The Paradigm for New Buildings – A ‘Positive Energy’ Return
Primary Energy Consumption is less than or equal to 15 kWh/m2/yr. Renewable Energy & Heating Systems then contribute a reliable quantity of energy, per year, which covers the following:
- the Building’s Primary Energy Consumption ;
- an Energy Efficiency Degradation Factor which takes account of the degradation in energy efficiency normally expected during the life cycle of renewable energy and heating systems installed in the building (the rate of degradation will depend on the quality of maintenance and servicing) … and caused by wasteful patterns of building management and/or use ;
- the energy consumed by Private Transport associated with the building ;
- an Energy Return to an Intelligent District or Regional Grid exceeding, by a whole number multiple determined by reference to local conditions, the total energy consumed by the Building (including its Energy Efficiency Degradation Factor) and any associated Private Transport.
Uniquely, this more practical elaboration of the innovative concept of Positive Energy Buildings considers life cycle energy efficiency degradation.
BER Certificates, Legislation & Thermal Comfort (I)
The recent comment submitted by Mr. Robin Evans regarding the use of Infra-Red Thermography as an aid to BER Assessment … and the high level of confusion and misinformation in the marketplace, which I have now had an opportunity to examine more closely … have forced me to conclude that a series of posts on BER Certificates would be good for the system - ‘my’ system !
There are many pieces in this jig-saw puzzle, but the final picture is wonderful … please believe me.
Before I start to assemble anything, however, a few small details …
- Infra-Red Thermography. This is a valuable technical aid during any Energy Survey of any Building. It is remarkable how much information can be gathered by a good, high-resolution Infra-Red Camera. But, it must be used competently … Because we are working in ambient temperature conditions, i.e. between -10OC and +30 OC, it should be a Long Wave Infra-Red Camera (≈ 8-12 microns). The temperature difference between the inside of the building and the exterior should be at least 10 degrees C … it would be better with 15 degrees C. The Camera Operator should be fully familiar with the operation of the Camera and its associated computer software, etc … and he/she should know what they are looking at. In other words, some sort of architectural background is essential … not only are images taken outside the building, but they are also taken inside the building ! Any Camera Work should be done after dark. It is not necessary to do a midnight to 4 o’clock in the morning shift … 8 o’clock in the evening until midnight is perfectly fine. By the way, none of this work can be done in just 30 minutes. Finally, Infra-Red Work is best carried out, in Ireland, during the Heating Season, i.e. the months of November through to March. Depending on the year, it may be possible to squeeze in the end of October and the beginning of April.
In the old days, I used to work as part of a Multi-Disciplinary Team of 4 People (not all males !), comprising a Civil Engineer, a Physicist/Expert in Measurement, an Engineering Technician with a background in Social Science, and myself as Architect/Fire Engineer/Technical Controller. They were great days !
Robin … in order to provide this service for the owner of a typical suburban, semi-detached house … €100 (Euros) is a little on the low side, even as a ‘lost leader’.
And … the Irish Public are indeed blissfully unaware of the efficacy of Infra-Red Thermography. The ‘powers that be’ in Ireland, i.e. the Department of the Environment, Heritage & Local Government (DEHLG), Energy Ireland (SEI) and the Construction Industry Federation (CIF), are not at all interested in the ‘real’ energy performance of buildings. They have a vested interest in not being interested. Suddenly … the image of an ostrich, with head deeply embedded in sand, floods my mind …
Colour Clip Art Image of an Ostrich, with head deeply embedded in sand. Meanwhile, in the background, an hourglass signals that time is running out !
- BER Certificates & EU/National Legislation. Mr. Charlie McCreevy, Ireland’s EU Commissioner, during one of his many ‘direct, pragmatic and neo-liberal’ talks in Dublin, used the following magnificent phrase in relation to the national implementation of European Union Legislation in the different EU Member States … ‘National Gold Plating and Divergent Implementation’ … some important words to remember ! However, I learned this valuable lesson myself a long, long time ago.
Irish National Legislation: Statutory Instrument No. 666 of 2006: European Communities (Energy Performance of Buildings) Regulations 2006.
These Regulations may be unconstitutional. A prime example … Section 23 (1) states that a person authorised by Energy Ireland (SEI) under the Regulations … ‘may enter, inspect and examine a building or any part of a building for the purpose of forming an opinion as to whether or not a BER Data File or BER Certificate issued for the building, or part of the building, is warranted’. In relation to a private, single-occupation dwelling house … this provision is entirely unacceptable !
The Register of BER Assessors on the SEI WebSite is not reliable.
Because of ‘national gold plating and divergent implementation’ in Ireland, it is necessary to be familiar, also, with the originating EU Secondary Legislation.
European Union Legislation: EU Directive 2002/91/EC of the European Parliament and of the Council, of 16 December 2002, on the Energy Performance of Buildings.
Both pieces of legislation can be downloaded from the SDI WebSite … here.
- Thermal Comfort in Buildings. The starting point for any discussion about this subject should be an International Standard, which is also the European Standard and the Irish National Standard … ISO 7730 Moderate Thermal Environments – Determination of the PMV and PPD Indices and Specification of the Conditions for Thermal Comfort.
This Standard establishes the following important general principle … and is also critical in relation to people with activity limitations who use/occupy/visit buildings: Man’s/Woman’s Thermal Sensation is mainly related to the thermal balance of his/her body as a whole. This balance is influenced by his/her physical activity and clothing, as well as the environmental parameters: air temperature, mean radiant temperature, air velocity (i.e. draughts) and air humidity.
Air Temperature, alone, is definitely not an Indicator of Thermal Comfort in a building.
- Technical Control of Construction. The 2005 & 2008 NIST Reports on the 9-11 WTC Incident have presented us with some stark language … ‘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.’
With regard to Private Construction in Ireland … Building Control Authorities in Ireland are, purposefully, not sufficiently resourced to be ‘effective’. See my earlier Post, dated 2009-02-12.
With regard to Public Construction in Ireland … self-regulation is no regulation ! Government Departments, the Office of Public Works and Local Authorities can, far too often, be complacent, careless and/or stubborn concerning compliance with even the minimal performance levels specified in building regulations, codes and standards.
Quality of Irish Construction – Unacceptable ?
So … Anglo-Irish Bank has been caught – finally – playing with numbers and cooking the books. And … because of inadequate (i.e. a complete lack of effective) control by the National Financial Regulator, this was regarded as a routine, ‘smart’ transaction by privileged individuals. “What is the problem ?” … they ask … “no laws were being broken”.
Holding firmly onto those thoughts, let us briefly turn our attention to the Construction Sector … and the Energy Performance of Buildings …
A new Home Energy Savings (HES) Scheme was recently announced by Mr. Eamon Ryan T.D., Minister of Communications, Energy & Natural Resources … €100 million Insulation Scheme to Benefit 50,000 Homes – Programme Will Create 4,000 Jobs … according to an article in The Irish Times, on Monday 9th February 2009, by Mr. Harry McGee.
Reading the Department of Energy’s own Press Release for the Scheme Launch, dated 2009-02-08 … it is evident that public relations consultants, marketing gurus, senior academics (who should know better) and civil servants were involved in producing ‘paper’ numbers to justify and support the miserable grants being offered in the HES Scheme. Numbers were even presented for ‘Typical Net BER Improvement’ ?!?
When the Scheme is eventually up and running, Thermal Insulation Contractors will be required to comply with a voluntary Energy Ireland (SEI) ‘Contractors Code of Practice & Standards and Specifications Guidelines’ (version 1, 2009-02-03) … and SEI may or may not carry out control inspections in order to monitor the quality of their work. Does all this sound familiar ?
But … are these paper energy numbers ‘real’ ? If he thinks so, Mr. Eamon Ryan is living in Alice’s Wonderland !
This is a photograph, taken back in 2000, of expanded polystyrene insulation which was badly installed in an external cavity wall … very badly installed ! When the Irish Construction Industry would later enter extreme ‘over-heat’ mode, the quality of typical construction would deteriorate sharply.
Colour Photograph of an External Cavity Wall, showing 'Floating' Thermal Insulation (and, in the background, an Inclined Steel Wall Tie which will later facilitate water ingress). Click to enlarge. Photograph taken by CJ Walsh. 2000-01-19.
Who can know what is happening inside that cavity when it is all finished and covered up from view ? Nobody. Unless, that is, you manage to take an Infra-Red Thermal Image during the next winter heating season – which is far too late to remedy the problem.
This is an example of an Infra-Red Thermal Image, taken back in 1998 …
Colour Image, with explanatory Text and Horizontal Temperature Bar below, showing the 'Real' Energy Performance of a Building. Click to enlarge. Project Architect: CJ Walsh. Image taken by sub-contractor in 1998.
Explaining the Current Context in Ireland …
It was 10 Years after the Dublin Stardust Fire Tragedy (February 1981) … before the first legal, National Building Regulations were introduced (December 1991); they became operational during the following summer of 1992. Around the same time, Building Control Authorities were being established in every Local Authority.
Prior to this, legal Building Bye-Laws were operated in just a small number of our major urban centres.
Dublin Corporation’s Bye-Laws with respect to the Construction of Buildings, adopted by Dublin City Council on 27th June 1949, were an interesting mix of functional, performance and prescriptive requirements. An Application, containing detailed construction information, for Building Bye-Law Approval had to be made for every construction project … and I mean ‘every’ project … prior to any construction commencing. And, ‘every’ project was inspected at the foundation and drainage stages of construction … no exceptions. The more complex projects were inspected as they progressed further, with special attention being paid, for example, to fire safety related construction. I know, first-hand, that the surveyors and inspectors in Dublin Corporation’s (as it was then called) Building Control Section had built up a considerable wealth of knowledge and understanding about construction conditions and practices right around the city and suburbs.
Anyway … after the introduction of the National Building Regulations, an unwritten national policy was put into action … having as an aim the winding down, and general ‘castration’, of the large, well-established Building Control Sections in Dublin City and County, and Cork. Meanwhile … in the rush to establish the new Building Control Authorities throughout the rest of the country, it was common to hear of Road Engineers being transferred into the new Control Authorities … usually having little or no experience in dealing with the construction of buildings.
Site Inspections under our current system of National Building Regulations are random. Inspection Statistics produced by the Department of the Environment, Heritage & Local Government (DEHLG) are not reliable. Building Control Authorities are, purposefully, not sufficiently resourced to be ‘effective’.
Commencement Notices, under the National Building Control Regulations, do not have to be accompanied by detailed construction information when being submitted to a Building Control Authority.
Fire Safety Certificates, under the National Building Control Regulations, do not involve any Site Inspections – at any stage – by Fire Authorities.
Some Conclusions …
The above is a rather long, but simplified, explanation as to why a large number of privileged property developers and shoddy building contractors have been allowed to flourish on Irish Construction Sites without ever understanding the concept of ‘effective’ technical control. When they do eventually meet this concept, head-on, the level of their resentment can be without limit.
Before the recent property crash, did you ever try to present a builder with a Snag List on a new house ?
This will also put SEI’s 70% rate of non-compliance into an understandable context. See my earlier Post, dated 2008-12-12.
With regard to BER Certificates … BER Assessors without any sort of architectural background are not competent to assess the construction of existing buildings … and those BER Assessors with an architectural background cannot possibly evaluate, with reliability, the construction of existing buildings without the use, for example, of Infra-Red Thermography and Air Seepage Testing.
BER Assessment of Historical Buildings is unsuitable, and not appropriate.
An Energy Survey of a Building is an entirely different concept to a BER Assessment. See our Technical Guidance Note No.95/101(a).
Building Energy Rating (BER) Certificates – Worried ?
Thursday, 1 January 2009, is fast approaching, and any person offering an existing house for sale or rent around this time is being bombarded by all sorts of ‘marketing blurbs’ in the different media about having to produce a BER Certificate.
Don’t be worried.
When in doubt, go directly to the actual legislation … and in this case, it is Statutory Instrument No.666 of 2006: European Communities (Energy Performance of Buildings) Regulations 2006.
Legislation cannot be retrospective … so, if a house has already been offered for sale or rent before 1 January 2009, no BER Certificate is required.
Colour image of an Irish BER Certificate. See S.I. No.666 of 2006: European Communities (Energy Performance of Buildings) Regulations. Click to enlarge.
And … if you care to look at the text on one of these ‘certificates’ (in the top right-hand corner), you will notice the following …
” The Building Energy Rating (BER) is an indication of the energy performance of this dwelling.”
However, unless long wave infra-red thermography has been used under proper conditions, by a competent person, as part of a comprehensive energy survey of the house … and thermal images were taken … and other accurate and precise information was gathered about the actual energy performance of this specific house … the statement in the BER Certificate is misleading.
There is only a very tenuous relationship between a BER Certificate and the ‘real’ energy performance of a specific building.
What’s more …. Energy Ireland (SEI) knows full well that this is the case.
In addition, as if that were not bad enough …. Energy Ireland (SEI) have been sitting on a Report for approximately 3 years which indicates that there is a general non-compliance rate of 70% (that’s right folks !) with the minimal – some might say “abysmal” – energy performance requirements, which apply to new houses, in Part L of the Irish Building Regulations.
And …. because everybody can see that our national system of building/technical control in Ireland is entirely inadequate, that figure of 70% non-compliance may be an underestimate.
Many, many months ago, I asked for a copy of this SEI Report.
I am still waiting.
[2009-01-12 Who did I ask ? Mr. Brendan Halligan, SEI Board Chairperson & Mr. Kevin O'Rourke, SEI Head of Built Environment !]
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