CJ Walsh
Accessibility-for-All at the Brussels European Parliament ?!?!
Last Wednesday (2010-02-24), I was very pleased to be in Brussels to attend the Inaugural Meeting of the European Parliament’s URBAN InterGroup for the New Parliamentary Term. Being very curious, however, there was no way … no way at all … that I could enter the Parliament Building without checking on a specific part of the Early Parliamentary Complex on Rue Wiertz … for any improvements to its past, woeful ‘accessibility’ performance. Please note that I am not referring, here, to transport issues … but to ‘accessibility’ for people with activity limitations.
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Colour photograph showing the same dangerous external ramp/stair combination near the Main Public Entrance to the European Parliament Building, on Rue Wiertz, in Brussels. During rush hour periods of the working day, this ramp/stair combination is a very busy public pedestrian route. Click to enlarge. This photograph taken by CJ Walsh. 2010-02-24. For more photographs of this architectural 'gem', dating from 2000-2001, see SDI's Corporate WebSite.
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Since the 2006 United Nations Convention on the Rights of Persons with Disabilities became an International Legal Instrument on 3rd May 2008 … people with activity limitations now have a clearly defined right, under international law, to be able to access and use the Built Environment. They also have the right to receive an equal and meaningful consideration in situations of risk, e.g. when there is a fire in a building. The language of the Convention is unusually strong.
Once upon a time … 9 or 10 years ago … at the beginning of this decade/century/millennium … a Properly Accessible Built Environment could only be wishful thinking. Yes, there was some legislation … usually very weak … at national level in the E.U. Member States … but nobody paid much attention to implementation. The least that could be expected, however, was that Iconic Buildings purposefully intended and designed for occupation by Institutions of the European Union would be examples of ‘good accessibility’ … as so much emphasis has always been placed in the E.U. Treaties, including the New Lisbon Treaty … on the foundation of the European Union being robustly rooted in Human and Social Rights for All … not just a privileged few, or a self-contented majority.
At this Page on Sustainable Design International’s Corporate WebSite … www.sustainable-design.ie/arch/inaccesseubuildings.htm … I recorded the dismal and depressing evidence on the ‘inaccessibility’ of both the Brussels and Strasbourg Parliament Buildings at that time.
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Colour photograph showing the 'special' entrance reserved for 'personnes a mobilite reduite' in another part of the Brussels European Parliamentary Complex. It's too bad if someone who must use this facility cannot understand the incorrectly printed French ! Click to enlarge. Photograph taken by CJ Walsh. 2010-02-24.
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So … what has changed in the intervening years ? Have there been any improvements to a situation which I originally described as being ‘stupid and ridiculous’ ? [I won't bore you with all of the reasons why.] Or, are things worse ? Have we, in fact, entered into some unknown region of The Twilight Zone ? Arise again GUBU (Grotesque, Unbelievable, Bizarre and Unprecedented) !!
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Colour photograph showing the Main Entrances associated with the 'special' entrance in the photograph above. They are located approximately 10 metres around the corner on a different side of the building. If the nosings of those steps have been highlighted in yellow, does that mean that these clumsy entrances are 'safe' ?? Click to enlarge. Photograph taken by CJ Walsh. 2010-02-24.
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Pinch yourselves, a few times, as you examine the photographs closely ! Try to remember that these buildings are not renovated or refurbished existing buildings. They were all designed and constructed, as ‘new’, on cleared sites within the city !!
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Although Architects, the Brussels Local Authorities and the E.U. Institutions are primarily responsible for ‘inaccessibility’ of the Brussels European Parliament Building … we cannot afford to be smug or complacent in Ireland. Just look around you !
Again, once upon a time … towards the end of the 1980′s this time … I submitted the following Proposal for a Resolution on Accessibility-for-All to the Council of the Royal Institute of the Architects of Ireland (RIAI) … please forgive the pre 2001 WHO ICF use of language and terminology …
Preamble
The elimination of architectural barriers to mobility of the disabled is an essential and preliminary condition for successful implementation of the principal that all people should be fully integrated into society, participating in and contributing to all aspects of economic and social life.
Resolution
Celebrating the 150th year of its establishment, Council of the Royal Institute of the Architects of Ireland asks all Members:-
(i) to note the principal that all people should be fully integrated into society, participating in and contributing to all aspects of economic and social life ;
(ii) to eliminate as far as reasonably practicable, in the design of buildings, architectural barriers to mobility of the disabled.
Was this Resolution passed ? I’ll give you one guess ! The reason given, at the time, was that the Profession might be viewed as being culpable … which it was … and remains to this day. The source of this culpability, however, is most definitely the Schools of Architecture.
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2010 ACRECONF in Delhi (Dilli), India – 8th & 9th January
It was a great pleasure to be invited to speak on the subject of Sustainable Fire Engineering at the 2010 ACRECONF in Delhi (Dilli), India. This ground breaking conference in Asia took place at the India Habitat Centre, Lodhi Road, Delhi … on the 8th & 9th January last. Back during August (2009) in Bengaluru … the ACRECONF Chairman, Mr. Ashish Rakheja, told me that he expected an attendance of somewhere between 500-600 people at the Delhi Conference. Over the two days of the actual conference, approximately 1800 delegates participated … an enormous response by architects, civil and service engineers, developers, client and construction organizations, etc., etc., from right across the country … and from the deep south.

Colour photograph showing some of the many participants at the 2010 ACRECONF in Delhi, as they enjoy talking and networking during the morning coffee break of the second day at the conference. The venue was the India Habitat Centre on Lodhi Road. The weather was chilly for the time of year, and there had been a heavy fog earlier in the morning. Click to enlarge. Photograph taken by CJ Walsh. 2010-01-09.
For me … refreshing, extremely impressive, and certainly the highlight of the conference … was a multi-media presentation … on the second morning, just after the coffee break … by Mr. Karan Grover, the renowned Indian Architect. He is quite an individual !
Before the break, delegates had been treated to an elaboration of the Environmental Design Innovations incorporated into the 71 storey Pearl River Tower (Guangzhou, China), by Mr. Varun Kohli of Skidmore, Owings & Merrill (SOM) in New York. Construction of the Tower is now well under way. Afterwards, however, an important discussion took place concerning the issue of fire safety, and fire engineering generally, in Sustainable Buildings. It became clear to all of the participants that this issue is a major oversight … an intentional gap … in the design of these buildings. I made the point, forcibly, that Sustainable Fire Engineering is open to innovation and design creativity. There will be an important follow-up to this discussion.

Colour photograph showing a silly tourist on a bicycle rickshaw, as he is brought sightseeing around the Bazaar District in Old Delhi. Click to enlarge. Photograph taken by Mr. Daljeet Singh, Ministry of Tourism, with CJ Walsh's camera. 2010-01-09.
Unfortunately, the conference was peppered with references to ‘Green’ Buildings … an outdated marketing concept (!) … which, within its limited world-view, gives people the false comfort of not having to deal with thorny issues such as ‘social justice, solidarity & inclusion for all’. I have discussed this issue many times in previous posts.
Even more unfortunately, where the Brundtland Definition of ‘Sustainable Development’ was actually presented in one session … as usual, it was only the first half of the definition which made any appearance. The second, and more important, half of the definition had mysteriously vanished without trace … which made the whole effort a meaningless exercise ! What a waste !! No wonder there is such confusion over the concept … at all levels … in most countries !!!
It was not surprising, therefore, that what was not stressed enough, during the entire conference, was that Sustainable Design Solutions must be appropriate to local geography, climate, economy, culture, social need and language(s)/dialect(s), etc. The LEED Building Rating System (USA), for example, is not being properly adapted to local conditions in India !
A final issue … another major oversight … another intentional gap … in the design of buildings … Accessibility-for-All ! Even though India ratified the 2006 UN Convention on the Rights of Persons with Disabilities on 1st October 2007 … this essential aspect of design … certainly in Sustainable Buildings … received no mention whatever during the conference … except by yours truly, in my presentation.
Overall … a magnificent achievement for the organizers !
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BATIMAT Building Exhibition in Paris (2-7 November 2009)
Here we are, once again, approaching November 2009. Two years have rolled by … far too quickly … since the last Paris BATIMAT Exhibition in 2007.
Compared to what we are used to in Ireland, the BATIMAT Exhibition is huge … taking at least 3-4 days in order to see everything half-decently !

Annotated, colour image showing the 2009 Paris BATIMAT Exhibition Site Layout and general information about dates (2-7 November), opening times (every morning, from 09.00 hrs), etc. Click to enlarge. Extract from Official Exhibition Catalogue.
I have been going there for many years … to spot new trends, discover innovative building products and systems … and meet up with friends from CSTB or CTICM. In a good year, I would expect to find at least 7-8 good new ideas …

Colour photograph showing an exterior view looking up the main avenue towards Pavillon (Hall) 7. Click to enlarge. Photograph taken by CJ Walsh. 2001-11-09.
When I first enter the Exhibition, I usually become emotional … almost close to tears … not at the enormous scale of the event … but because so much on view never appears in the Irish Construction Product Marketplace … and if they do appear, it is not until many years later. I kid you not ! There are reasons … but, that is a discussion for another day …

Colour photograph showing an interior view looking over Pavillon (Hall) 1. Click to enlarge. Photograph taken by CJ Walsh. 2001-11-09.
I wonder if the Current Recession in the European Construction Sector will have an adverse impact on this year’s exhibition.
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‘Sustainable Fire Engineering’ – Important Keynote Presentation at Indian National Fire Seminar
It is really enjoyable to be back behind my desk, here in Dublin. Apologies for the prolonged absence.
Since the middle of June last, my travels have taken me to Turkey, France, Italy, the south-west of Ireland to attend my cousin’s wedding in Cork … and back again to Bengaluru (Bangalore) in Southern India to make an important Keynote Presentation at the 2009 Fire & Safety Association of India (FSAI) National Fire Seminar: ‘Engineering a Safe & Secure India’, which was held on Friday, 28th August, at the Leela Palace Hotel.
My Presentation Title & Abstract …
Sustainable Fire Engineering: Fire Safety, Protection & Evacuation for All
India, like other economically advanced developing countries, is at an important crossroads. Difficult, resource-dependent decisions must be made in the next few short years concerning the rapid implementation of a Sustainable Built Environment across a vast country, i.e. one which must serve local needs and meet regional performance requirements during a long life cycle … one which will be adaptable to climate change, variability and extremes … will be in harmony and dynamic balance with the Natural Environment … and, not least, will be super energy-efficient.
Citizens of Developed Nations also have legitimate expectations. They will express anger when they witness recently constructed buildings in seismic zones collapse, in an earthquake, like a deck of cards (China 2008, Italy 2009) … or they discover that federal/state authorities having jurisdiction, which are funded by their taxes, are ill-prepared to respond effectively to intentional traumatic disruptions to the Social Environment (New York 2001, Mumbai 2008). Retaining the public’s confidence in national institutions is a fundamental political priority.
In the case of all new High-Rise Buildings, Iconic Buildings, and Buildings of Innovative Design or having a Critical Function … Trans-Disciplinary Building Design Teams must, at a minimum, properly respond to the Recommendations of the 2005 & 2008 NIST(USA) Final Reports on the 9-11 WTC 1, 2, and 7 Collapses. In practice, the majority of these Recommendations should be applied to the design of all new buildings !
Fire Engineers, competent concerning the processes of ‘real’ building design and construction, must begin to understand the ‘real’ people who occupy or use buildings, every day of every week, in all parts of India … and that they each have widely differing ranges of human abilities and activity limitations. Just as they are different from each other, they will react differently than expected in a ‘real’ building fire emergency.
Based on a Keynote Presentation before International Council for Building Research (CIB) Working Commission 14 : Fire and Sub-Committee 3 & 4 Members of ISO Technical Committee 92 : Fire Safety, at Lund University in Sweden … and his fire safety texts which have been fully incorporated into International Standard ISO DIS 21542 on Accessibility-for-All, currently under development and due for publication before the end of 2010 … CJ Walsh’s Presentation, at the FSAI National Fire Seminar in Bengaluru, will focus on ‘Fire Safety, Protection & Evacuation for All’.
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Architectural & Structural Engineering Design for Robustness !
Earlier in the year … a certain non-native English speaking colleague of mine, who is very active in European and International standardization work (and has very good English !), had never heard of the word ‘robust’. She just could not get her head around either the word or the concept … and thought I was making it all up !
Fast forward a few months … and as a long-time member of the International Association for Bridge & Structural Engineering (IABSE), an occasional ‘freebie’ lands on my desk. This one was a real treat !
Published by IABSE in Switzerland … Structural Engineering Document #11: Design for Robustness … was written, in language accessible to both structural engineers and architects alike, by Franz Knoll and Thomas Vogel.
The objective of these Structural Engineering Documents is to provide in-depth information to practicing architects and structural engineers, in reports of high scientific and technical standards, on a wide range of structural engineering topics.
Check out the IABSE Website … http://www.iabse.org/publications/orderform/ … and get yourself a copy … pronto !
In previous posts concerning Areas of Rescue Assistance in Buildings, for example, I have often referred to robust, fire resisting construction.
And the further development of Fire-Induced Progressive Collapse … will inevitably take place within wider considerations of Robustness.
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BS 9999:2008 & BS 8300:2009 – Sleepwalking into Problems ?
Ireland has no national standard codes of practice of its own covering building accessibility or fire safety in buildings. Instead, many people and organizations in this country will just switch to automatic pilot and – without thinking or questioning – adopt the following two standards of another jurisdiction as the default Irish national standards …
British Standard BS 9999:2008 – Code of Practice for Fire Safety in the Design, Management and Use of Buildings … was published on 31 October 2008.
British Standard BS 8300:2009 – Design of Buildings and Their Approaches to Meet the Needs of Disabled People. This Code of Practice was published on 28 February 2009.
If Ireland does not quickly open its eyes … we will be sleep walking into a very problematic legal environment, as far as building accessibility and fire safety in buildings is concerned.
1. An Immediate Challenge
How to develop a set of practical proposals, suitable for application in Ireland and compatible with European technical harmonization, on the following issues:
i) Clear Width of Internal & External Door Openings ;
ii) Turning Circles for Occupied Wheelchairs ;
iii) Car Parking Spaces ;
iv) Fire Safety Issues.
And how to encourage … given the absence of Irish national standards … the implementation of these proposals as part of everyday good accessibility design practice in this country.
2. Overview of BS 8300:2009 & BS 9999:2008
During the development of the Draft ISO Accessibility-for-All Standard, it has been unanimously agreed that Accessibility encompasses the full range of activity related to buildings: to approach, enter, use, egress from and evacuate a building independently, in an equitable and dignified manner (Introduction, 2nd Paragraph, Page 5). ‘Egress’ under normal, ambient conditions is distinguished from ‘Evacuation’ in the event of a fire emergency. Use of the word ‘Escape’ is discouraged in any circumstance. For the first time, fire safety texts have been fully incorporated into the main body of the Draft ISO Standard.
Accessibility within the British Standards Institution (BSI), on the other hand, is still segregated between BS 8300:2009 – approach, entry and use and BS 9999:2008 – fire evacuation. Conflicts and gaps in content naturally result from such a configuration, which can now be seen as outdated and fundamentally flawed.
This configuration has been replicated, in Irish Building Regulations, with the separate scopes of Part M / Technical Guidance Document M and Part B / Technical Guidance Document B. Integration between these 2 Technical Guidance Documents is very poor. In practice, fire safety for people with activity limitations is widely disregarded within the process of Fire Safety Certification.
2.1 BS 8300:2009
BSI has arrogantly gone on a solo run, and decided to deviate from some very widely accepted concepts of accessibility, e.g. ‘clear width’ of a door opening (discussed in more detail later). The ‘Ergonomic Research’ supporting door opening forces of 30 N is at complete variance with earlier research in Britain and must, therefore, be strongly questioned. Perhaps, it is the case that the Fire Services in England & Wales re-asserted their authority, supported by reference to European Fire Product Standards with little if any input from the European Disability Sector, and insisted on a ‘definite’, i.e. high, closing force being exerted on the door leaves in fire resisting doorsets.
2.2 BS 9999:2008
People with disabilities have a right, recognized in international law after 3rd May 2008, to equal opportunity and non-discrimination in matters of building fire safety, protection and evacuation. A minimum response to Article 11 (Situations of Risk) in the 2006 United Nations Convention on the Rights of Persons with Disabilities is required, therefore, from fire regulators and code writers. Such a response is absent in British Standard BS 9999:2008.
A close examination of the fire safety texts relating to ‘disability’ in BS 9999:2008 shows that they have not been properly integrated into the ‘mainstream’ content. In fact, much of the content from the replaced BS 5588:Part 8 has just been grafted onto BS 9999, with very little change or alteration from the first version of Part 8 published in 1988 !
Compare Figure G.1 on Page 360 of BS 9999:2008 … with … Figure 4 on Page 8 of BS 5588:Part 8:1988 … both are exactly the same …

Black and white drawing showing both a token and an inadequate 'area of rescue assistance' in BS 9999:2008 - exactly as shown in the first version of BS 5588:Part 8 published back in 1988 ! Click to enlarge.
Two Critical Observations in relation to the ‘area of rescue assistance’ shown above:
- This drawing in BS 9999:2008 is in direct conflict with the text located directly above it … ‘where the wheelchair space is within a protected stairway, access to the wheelchair space should not obstruct the flow of persons escaping’ ;
but, more importantly …
- In BS 9999:2008, fire safety for people with activity limitations receives treatment which is superficial and merely token. Many times in relation to buildings generally, it is stated in Annex G.1, Page 359 …
‘A refuge needs to be of sufficient size both to accommodate a wheelchair and to allow the user to manoeuvre into the wheelchair space without undue difficulty.’
’In most premises, it is considered reasonable to have refuges of a size where each one is able to accommodate one wheelchair user. Where it is reasonably foreseeable that the proportion of disabled users in a building will be relatively high, or where the use of the premises is likely to result in groups of wheelchair users being present (e.g. some types of sporting, entertainment, transport or public assembly buildings), consideration should be given to increasing the size and/or number of refuges accordingly.’
’NOTE 3 Managers of sporting or other venues where a number of disabled people might be present are advised not to restrict the number of disabled people who can be admitted to that venue on the grounds of the size of refuges, since some disabled people who use mobility aids such as a wheelchair will be able to self-evacuate in the case of a real fire.’
and again in Annex G.2.2 on Page 367 …
‘Where it is reasonably foreseeable that the refuges will be used by more than one user (e.g. some types of sporting, entertainment, transport or public assembly buildings), … ‘
Within such an inadequate and token context, it is understandable that an unduly heavy reliance is placed on the practice of developing Personal Emergency Evacuation Plans (PEEPS) for individuals with activity limitations. See Paragraph #46.7a) on Page 248, which states …
‘By taking into account the individual needs of a person when preparing a PEEP, management will be able to make any reasonable adjustments to the premises or procedures that are necessary.’
These Plans are flawed and discriminatory because they are:
- person specific ; and
- location specific ;
… with the underlying assumption in the text being that, beyond the specified location(s), the building is not properly accessible, i.e. does not meet the functional requirements of Parts B & M in the Building Regulations for England & Wales – or, in the case of Ireland, Parts B & M of our Building Regulations.
There are silly technical errors in BS 9999:2008, e.g. in Annex G.2.3 on Page 368, it states …
‘Unless a different order has been agreed with the fire authority, evacuation should normally be in the following order:
1) the fire floor ;
2) the floor immediately above the fire floor ; [This should read 'the floors immediately above and immediately below the fire floor' !]
3) other floors above the fire floor starting at the top storey ;
4) all remaining floors.’
A Technical Term is used in BS 9999:2008 – Place of Ultimate Safety – which complicates the already widely accepted term: ‘Place of Safety’. The definition provided for the British Term in Section 3: Terms & Definitions (#3.84, Page 17) is so vague that it is of no practical use to fire engineering designers, building managers or building users.
3. Comments: i) Clear Width of Door Openings
Paragraph #6.4.1, on Page 36 of BS 8300:2009 introduces a new understanding of ‘clear width’ for door openings, which is illustrated in Figure 11 (Page 37) … and also a new term ‘effective clear width’.
The new understanding of ‘clear width’ is a complete departure from the standard understanding, widely accepted throughout the world, which is shown in the bottom left hand drawing of Figure 11.
The new term ‘effective clear width’ will complicate the already difficult concept of ‘clear width’. Wasn’t the ‘clear width’ of a door opening always supposed to be ‘effective’, i.e. properly permit circulation for wheelchair users ?
However, the issue raised in the top right hand drawing of Figure 11 is valid …

Colour photograph showing the Final Fire Exit from a building (somewhere in Ireland). The 'clear width' of the door opening is seriously compromised - the door leaf cannot be fully opened and the panic bar reduces the 'clear width' still more. Click to enlarge.
Solution: Retain the current international/European/national understanding of ‘clear width’ for door openings in Ireland … but include text, with supporting drawings, in Revised Technical Guidance Documents B & M to ensure that there is no encroachment on that ‘clear width’ caused by protruding door leaf ironmongery or, more importantly, where the door leaf itself cannot be fully opened to 90o-100o.
4. Comments: i) Clear Width of Door Openings in Existing Buildings
Table 2, on Page 37 of BS 8300:2009, permits the ‘clear width’ for door openings in existing buildings to be reduced significantly below 800mm.
If buildings of historical, architectural and cultural importance are properly identified, and proper allowance is made for these specific building types in Revised Technical Guidance Documents B & M … there is no need to permit a general reduction in the ‘clear width’ for door openings in existing buildings.
Solution: Clearly indicate in the Revised Technical Guidance Document M that the last ‘Existing Buildings’ Column on the right of Table 2 in BS 8300 should be disregarded.
5. Comments: ii) Turning Circles for Occupied Wheelchairs
Down through the years, it has been just possible to communicate the concept of the ‘wheelchair turning circle’ to building designers and urban planners … whether it be the older 1.5m diameter circle or the newer 1.8m diameter circle.
The new Figures and Tables in Annexes C.3 and C.4 of BS 8300:2009 will be difficult to communicate … and may be a complication too far ?
6. Comments: iv) Fire Safety Issues

Colour photograph showing people trapped at the top of one of the WTC Towers. This Tower collapsed soon afterwards. Click to enlarge.
The Recommendations contained in the 2005 & 2008 National Institute of Standards & Technology (USA) Reports on the WTC 9-11 Incident in New York provide an invaluable and essential empirical basis for the practice of effective fire engineering design in today’s built environment.
The first of these two reports has special relevance for NSAI AASCC WG1 because the typical problems encountered by people with activity limitations during a ‘real’ building fire incident have been highlighted by NIST and closely investigated. As a result, three important fire engineering keywords have been re-stated with strong emphasis: ‘reality’ – ‘reliability’ – ‘redundancy’. And, a new key phrase in relation to way finding during evacuation has been introduced to the everyday practice of fire engineering design: ‘intuitive and obvious’.
The 2005 NIST Report, particularly, must be given proper consideration during the development of any reputable fire safety related standard or code of practice for the following reasons:
- at the time of the ‘real’ fire incident, approximately 8% of building users were people with disabilities, with 6% having mobility impairments ; [The percentage of 'building users with activity limitations' exceeded the 8% quoted above.]
- NIST found that the average surviving occupant in the buildings descended stairwells at about half the slowest speed previously measured for non-emergency/test evacuations. This raises a serious question over the use of standard movement times in fire engineering design calculations for evacuation ;
- NIST strongly recommended that fire-protected and structurally hardened lifts (elevators) should be installed in buildings to facilitate the evacuation of building users with disabilities, and to improve emergency response activities by providing timely emergency access to firefighters ; [In Ireland, building designers have already adopted this approach by constructing cores of reinforced concrete ... even in the absence of European/national standards.]
- it was recommended that evacuation routes should have consistent layouts, and be ‘intuitive and obvious’ for all building users, including visitors who may be unfamiliar with the building, during evacuations ;
- NIST recommended that staircase capacity and stair discharge door widths should be adequate to accommodate contraflow in circulation spaces, i.e. the simultaneous emergency access by firefighters into a building and towards a fire, while building users are still moving away from the fire and evacuating the building. This has implications for the minimum clear width of all fire evacuation staircases. Wider staircases facilitate the assisted evacuation and rescue of people with disabilities.
No consideration was given in BS 9999:2008, however, to any of the Recommendations contained in the 2005 & 2008 NIST Reports … there is not even a mention of either Report in the Bibliography (Pages 423-429).
- For such an important national standard in Europe – BS 9999:2008 – there is no understanding demonstrated of the Fundamental Functional Requirement for Public Safety in Buildings …
Buildings shall remain structurally stable and serviceable …
1. while people are waiting in ‘Areas of Rescue Assistance’ ; and
2. until all of these people can be rescued by Firefighters and can reach a ‘Place of Safety’, which is remote from a fire building – with an assurance of individual health, safety & welfare for the people involved ;
- There is a reference to ‘normal movement times’ which are used to calculate evacuation times in Mobility-Impaired People (Paragraph #46.2, Page 247), even though it was found by NIST that the average surviving occupant in the WTC Towers descended stairwells at about half the slowest speed previously measured for non-emergency evacuations. In a ‘real’ fire incident, there is no such thing as ‘normal’ or ‘standard’ evacuation movement times, and the idea that any building must be clear of occupants within a very short timeframe, e.g. 2.5-3.5 minutes, is ludicrous ;
- In the sensitive area of the Resistance to Damage of Enclosing and Separating Partitions (Paragraph #21.2.5 on Page 101) surrounding Firefighting Shafts, it is still permissible in BS 9999:2008 to use non-robust construction, e.g. lightweight plasterboard. Fire-Induced Progressive Collapse is not discussed in the BS 9999 … and neither is Disproportionate Collapse, which is one of the functional requirements – A3 – in Part A of the Building Regulations for England & Wales (and Ireland !) ;
- Although in Wheelchair Users (Paragraph #46.3 on Page 247), it is stated …
‘It should be noted that it can take as many as four people to use an evacuation chair safely and effectively.’
… the dimensions for the minimum width of staircases in Width of Escape Stairs (Table 14 on Page 88) and Firefighting Stairs (Paragraph #21.3.2 on Page 106) disregard the guidance given on Page 247 … and ignore the minimum staircase width (1.5m) required to safely assist the evacuation of a person in a manual wheelchair …

Black and white photograph (US FEMA 2002) showing the correct way to assist the fire evacuation of a wheelchair user in an evacuation staircase ... one person at each side, with another person behind.
And … for some unexplained reason, handrails are permitted to intrude into the ‘clear width’ of a firefighting staircase in BS 9999:2008 (Paragraph #21.3.2, Page 106).
Please note well … this method (shown below) of assisting the evacuation of a person in a manual wheelchair is incorrect. It is not possible to support any weight by holding the foot rests on a manual wheelchair, or by grasping the wheelchair by the front wheels …

Black & white sketch showing how definitely NOT to assist the fire evacuation of a wheelchair user in an evacuation staircase.
Manual handling of occupied wheelchairs in a fire evacuation staircase, even with adequate training for everyone directly and indirectly involved, is hazardous for the person in the wheelchair and those people – minimum three – giving assistance.
The weight of an average unoccupied powered wheelchair, alone, makes manual handling impractical. All lifts (elevators) in new buildings should, therefore, be capable of being used for evacuation in a fire situation. Lifts (elevators) in existing buildings, when being replaced or undergoing a major overhaul, should then be made capable of use for this purpose.
Contraflow Circulation, i.e. the simultaneous emergency access by firefighters into a building and towards a fire, while building users are still moving away from the fire and evacuating the building, has not been considered at all in BS 9999:2008.
A staircase width of 1.5m provides sufficient space for a mobile person to evacuate (700 mm) and a heavily protected and equipped firefighter to simultaneously move in the opposite direction (800 mm) …

Colour drawing, with photograph insets, showing the symbiotic relationship between Contraflow Circulation and Proper Assisted Evacuation in a building. Click to enlarge.
Human Behaviour in Fires should have been discussed in far more detail in BS 9999:2008 … but wasn’t. It is important for fire engineering designers to understand that the ‘real’ people who use ‘real’ buildings every day of every week, in all parts of the world, have widely differing ranges of human abilities and activity limitations … they are different from each other, and they will react differently in a fire emergency.
Building users need to be Skilled for Evacuation to a place, or places, of safety remote from a fire building. In the case of people with a mental or cognitive impairment, there is a particular need to encourage, foster and regularly practice the adaptive thinking which will be necessary during a ‘real’ fire evacuation.
Meaningful Consultation with every person known to occupy or use a building, for the purposes of receiving his/her active co-operation and obtaining his/her informed consent (involving a personal representative, if necessary), is an essential component of adequate pre-planning and preparation for a fire emergency.
Adequate Warning of a fire incident in a building should be communicated well in advance of the time when it is necessary to act and should continue for the full duration of the incident. Warnings should be informative, and easily assimilated in a form (e.g. oral, written, braille) and language understood by the people using the building.
Panic attacks, during evacuation in a ‘real’ fire incident, exist. The 2005 National Building Code of India refers extensively to this issue.
Solution: To resolve the technical inadequacies, inconsistencies and content gaps in BS 9999:2008 … it will be necessary to revise Technical Guidance Document B in Ireland. Fire safety, protection and evacuation from buildings for people with disabilities must be comprehensively included in the process of Fire Safety Certification.
7. Conclusions – BS 9999:2008 & BS 8300:2009
There are many gaps and conflicts between these two British Standards, principally because … they are two separate standards … drafted by two different Technical Committees within the British Standards Institution (BSI).
Because of its deviation from widely accepted concepts of accessibility and its tortuous use of terminology, BS 8003:2009 will have an adverse impact on the practice of Accessibility Design in Ireland … and has already complicated the development of the ISO Accessibility-for-All Standard (DIS ISO 21542).
Arrogance within BSI is not the only reason for such deviations. Distorting the European Union Single Market, for the purpose of introducing technical barriers to trade, is common in Britain … refer to the ‘deemed-to-satisfy’ status of the Approved Documents in the Building Regulations for England & Wales … and the Fire Protection Association’s ‘LPC Sprinkler Rules’.
Input from the Disability Sector during the drafting of BS 9999:2008 was not at all sufficient to ensure that there was a meaningful consideration of the problems encountered by people with activity limitations during a ‘real’ building fire incident. The necessary range of available and effective fire engineering solutions has not, therefore, been presented in the standard.
In addition, the complete and abject failure to consider the important Recommendations contained in the 2005 & 2008 National Institute of Standards & Technology (USA) Reports on the WTC 9-11 Incident in New York was an inexcusable and unforgivable technical oversight.
The result is a crassly inadequate, discriminatory and deeply flawed national fire safety standard in Great Britain & Northern Ireland. BS 9999:2008 became obsolete on the very day of its publication !
Postscript
Please refer to our 1999 Submission to the Department of the Environment & Local Government, in Dublin, concerning the use of British Standard BS 5588:Part 8 in Ireland …
http://www.sustainable-design.ie/arch/submissions.htm
Following this Submission, our understanding is that an ‘Internal’ Working Party was established within the Department. However, the Working Party never reported.
No proper response to this Submission has ever been received from the Minister or the Department.
On 29th November 2006, similar and very polite comments were sent directly to the British Standards Institution (BSI) by e-mail.
Receipt of this e-mail was never acknowledged by anyone in BSI.
The contents of the e-mail were ignored.
END
Institutions of National Governance – Criminally Dysfunctional ?
A week can be a long time in Ireland … during this last seven days, in particular, a time of harrowing emotions … horror, shame, disbelief, anger, pain, embarrassment … and relief that the truth has finally been revealed …
On Wednesday, 20th May 2009, at 14.30 hrs … the Report of the Commission to Inquire into Child Abuse was published at a launch, before a select audience, in Dublin’s Conrad Hotel. Victims of that child abuse and representative groups were barred, with the support of Gardaí, from attending.
Has anything really changed ?
The Commission was established on 23rd May 2000 … under the 2000 Commission to Inquire into Child Abuse Act (No.7 of 2000) … and given three primary functions:
- to hear evidence of abuse from persons who allege they suffered abuse in childhood, in institutions, during the period from 1940 or earlier, to the present day ;
- to conduct an inquiry into abuse of children in institutions during that period and, where satisfied that abuse occurred, to determine the causes, nature, circumstances and extent of such abuse ; and
- to prepare and publish reports on the results of the inquiry and on its recommendations in relation to dealing with the effects of such abuse.
The Chairperson of the Commission, Mr. Justice Seán Ryan, is a judge of the High Court.
The full Ryan Commission Report can be downloaded here … www.childabusecommission.com/rpt/pdfs/
Although Commission Recommendation No.5 (Volume IV, Chapter 7, Paragraph 7.06) states …
Childcare policy should be child-centred. The needs of the child should be paramount.
The overall policy of childcare should respect the rights and dignity of the child and have as its primary focus their safe care and welfare. Services should be tailored to the developmental, educational and health needs of the particular child. Adults entrusted with the care of children must prioritise the wellbeing and protection of those children above personal, professional or institutional loyalty.
[ Why is this critical Recommendation only in position '5' ? Concerning the rights and dignity of children, why is the word 'should' used instead of 'must' ? ]
… none of the 20 Commission Recommendations refer directly to the 1989 United Nations (OHCHR) Convention on the Rights of the Child, which became an International Legal Instrument on 2nd September 1990 … and which Ireland signed on 30th September 1990, and later ratified on 28th September 1992.
The Convention has not yet been fully incorporated into Irish National Law. Why not ?
In relation to Ireland, the UN (OHCHR) Committee on the Rights of the Child observed the following in late 2006 …
” … the Committee regrets that some of the concerns expressed and recommendations made have not yet been fully addressed, in particular those related to the status of the child as a rights-holder and the adoption of a child rights-based approach in policies and practices.”
Some Comments & Questions …
1. The Hierarchy of the Roman Catholic Church in Ireland (with the notable exception of Dublin Archbishop, Dr. Diarmuid Martin), the Catholic Religious Orders and the Catholic Church generally … have lost their moral authority … and all credibility. If child abuse was deeply in-grained and systemic in Ireland’s institutions … what was happening in institutions run by the 18(?) Irish Religious Congregations in other countries ? What assets have been transferred out of Ireland by the 18(?) Irish Religious Orders since the year 2000 ?
2. The Irish Government Ministry having jurisdiction … the Department of Education … has been clearly shown to be criminally dysfunctional. What radical changes in its organization, policies, practices and procedures will be put in place following the Ryan Commission Report ? We also ask the same question of the Department of Health & Children !
Perhaps Unnoticed … Another Institution …
Reported in an article on Page 4 of The Irish Times (2009-05-21) … on the same day that the Commission to Inquire into Child Abuse published its findings … 20th May 2009 … the family of a six-year-old girl, Sarah Jinks, who died in a fire on 10th January 1999 at a local authority house in Sligo, secured €115,000 in settlement of their High Court Action alleging that Sligo County Council had negligently failed to maintain a safe electrical system in the house. During the Action, Sarah’s mother, Ms. Philomena Jinks, had claimed that the Council failed to respond with sufficient thoroughness to complaints about dangers in the house.
The ‘Real’ Institution Involved …
Let me place in the public domain some revealing background to a series of fatal fires at a local authority housing estate on the far side of the country from Sligo … and a Letter, dated 22nd September 2005, which we were forced to write to Bray Town Council, in County Wicklow …

Colour photograph showing the scene after a fire in a terraced house at Oldcourt Housing Estate, Bray, Co. Wicklow. Click to enlarge. Photograph taken by CJ Walsh. 2005-08-18.
Mr. Seán O’Neill,
Town Engineer,
Comhairle Baile Bhré,
Civic Offices,
Main Street,
Bray,
Co. Wicklow.
Re: Fire Safety Survey of Oldcourt Estate, Bray.
Mr. O’Neill,
In good faith, we submitted a Tender Proposal (copy enclosed with the original letter) for a Fire Safety Survey of the Oldcourt Housing Estate to you. As of today, we have had no communication, written or oral, from Bray Town Council.
We fully understood the critical need for this to be an authoritative, competent, comprehensive and entirely independent Fire Safety Survey. Our principal concern was that this must be shown to be so, especially to local residents. We remain uniquely qualified, in Ireland and Europe, to complete the special and unique task involved.
It was with complete shock, dismay and alarm, however, that we saw our Organization actually named in Media Reports of discussions which took place at the September Council Meeting in Bray.
As a matter of public record, we now wish to clarify a few issues …
1. We commenced our work on the basis that the Tender Documentation issued by Bray Town Council was unreliable. This we were only able to do because of our extensive experience with Local Authority Housing, and the ‘ways’ and ‘means’ of Local Authorities in Ireland.
2. The Department of the Environment, Heritage & Local Government (DEHLG) has been intimately involved – at every level – with the planning, costing, design and construction of Local Authority Housing in every part of Ireland – from our direct experience, since the mid-1980′s. The Department is, therefore, very far from being a Disinterested Party in the serious matters under examination at the Oldcourt Housing Estate. It was extraordinary to see a representative of the DEHLG on the Interview Panel.
3. The Members of the Tender Interview Panel may have been ‘experts’, but we are not sure in which field. They showed little interest in our extensive practical experience of the complex area of fire engineering and its dynamic interaction with other aspects of performance in buildings and the built environment. It was necessary to explain some fundamental facts about the limited safety objectives of the Building Regulations to one Member. Some of the working methods necessary to effectively complete the Fire Safety Survey, of which we have direct and extensive experience, were unknown to all Members. It was clear that the Panels Members did not fully read our Tender Proposal.
4. At one stage in the Tender Interview, it was strongly ‘suggested’ to us that the Survey was to be a purely technical exercise, with no involvement whatever by the residents. At approximately the ‘two-thirds’ stage in the short interview, we realized that there was some ‘agenda’ in the background. We did not, therefore, make any final comments to the Panel.
We must now conclude that the Tender Process, organized by Bray Town Council, for a Fire Safety Survey of the Oldcourt Housing Estate appears to be corrupt. With deep regret, we hereby withdraw our Tender Proposal.
We require a full explanation as to why we have received no communication from you, or anybody else associated with Bray Town Council. We demand a full apology from the Council, and this must be published widely in the local and national media.
We are consulting with our legal advisors.
Signed: C. J. Walsh, Chief Technical Officer, FireOx International.
Copy: Ms. Deirdre deBurca, Chairperson, Bray Town Council.
[ No response has ever been received to this letter ... from any party. ]
And … we have not forgotten the deep corruption which went to the core of the Tribunal of Inquiry into the Stardust Fire Disaster.
A Long Delayed Evolution in International Fire Engineering ?
At my request … Agenda Item #6 for the CIB W14 Meeting, recently held on the campus of Lund University in Sweden (see post: 2009-04-30), covered the following subject …
‘ 2005 & 2008 NIST Recommendations on WTC 9-11 Incident – Fundamental Implications for Fire Engineering Design & Practice ‘
I began the presentation by explaining that architects are frustrated people at the best of times …
[It is a never ending, soul-destroying struggle to faithfully realize an architectural 'vision' on a building site ... especially in the absence of craftsmen/women and access to a wide range of well-designed, 'approved' construction products.]
… but, I have been intensely frustrated for some time … as a fire engineer … in particular, for the following reasons:
1. Negative, Irresponsible Attitude of European Lift Manufacturers
In order to effectively solve the issues of safe fire evacuation for people with activity limitations … and the timely evacuation of everyone in tall buildings … we must have lifts/elevators capable of being used for evacuation … all lifts/elevators … in all building types. This should be the norm … the standard specification.
Ever since 2003, however, when I was a Member of the European Union (EU) Expert Group on Accessibility, I have been pressing Mr. Luc Rivet, Secretary General of the European Lift Association (ELA) to ensure that the Association acts responsibly and makes this happen in Europe … now … not at any far distant point in the future. The time for ‘pretty’, meaningless talk at conferences, seminars and workshops has ended.
The ELA still refuses to act responsibly !
2. Crass Inadequacy of British Standard BS 9999 : 2008
Of interest to me … but not a cause for undue concern … except that far too many people in Ireland are already giving this Standard the status of Default Irish National Standard … and too many people in other countries are doing likewise …
On 31st October 2008, the British Standards Institute (BSI) published British Standard BS 9999 – Code of Practice for Fire Safety in the Design, Management and Use of Buildings. It took many years to draft this new national standard.
During all of that time, however, it is not clear to me that the simple idea of considering the Recommendations contained in the 2005 & 2008 NIST Reports on the WTC 9-11 Incident ever saw the light of day within the BSI Technical Committee which drafted BS 9999. The whole basis for the British Standard might have to be entirely re-examined … how awfully dreadful !?!
This amazing technical oversight has ensured that BS 9999 became inadequate on the very day that it was published.
Furthermore, although I had received assurances from certain people that British Standard 5588 : Part 8 would be properly incorporated into DD 9999 during the earlier stages of its development … in fact, this never happened.
Far too late in the drafting process, BS 5588 : Part 8 appears to have been shoe-horned into DD 9999. The resulting disability-related texts in the new Standard are vague … and represent a step backwards from BS 5588 : Part 8. And, there were many problems even with that earlier British Standard.
Finally, it has become blatantly obvious to me that nobody from BSI should ever again be allowed near the fire engineering terminology for any International or European Standards. BSI has polluted the international terminology of fire engineering.
Let me give you an irritating example which has had a seriously adverse impact on fire safety in buildings, in many countries, down through the years …
The term Fire Door has no meaning, and should not be used … Not Ever … Never !
It still leads to endless confusion on building sites … and very poor construction. It has been a disaster, in my own direct experience … and for everybody else associated with fire safety in buildings … including fire prevention officers in Local Authorities.
On the other hand, the term Fire Resisting Doorset / Shutter Assembly means:
‘ A doorset / shutter assembly, suitably installed or mounted on site, the function of which is to resist the passage of heat, smoke and flame for a specified time during a fire.’
A single concept … explained in simple language that anyone can understand.
I could go on about BSI and British Standards … but, I would rapidly bore myself to sleep !
Presentation at the CIB W14 Lund Meeting …
International Fire Engineering must – now – evolve as a direct result of the WTC 9-11 Incident in New York. This necessary evolution has been delayed for far too long by selfish vested interests.
And it is essential that an Empirical and Rational Basis is clearly identified for the practice of Fire Engineering Design in the 21st Century, i.e. after 9-11. Architects and Engineers, specifically, are desperately seeking reliable design guidance.

Colour image showing the Title Page (only) of CJ Walsh's Presentation: 'A Delayed Evolution in Fire Engineering ?', at the recent CIB W14 Meeting in Lund, Sweden. Originally scheduled for 2 Days, all commission business was efficiently completed on 23rd April 2009. Click to enlarge.
CJ Walsh’s CIB W14 Lund Presentation – PDF File (1.74Mb)
Click to download the Full Presentation
The Recommendations of the 2005 & 2008 NIST Reports must, at the very least, be applied to the design of ‘High-Rise’, ‘Iconic’, ‘Critical Function’ & ‘Innovative Design’ Buildings. In a previous post, dated 2009-01-13, I had proposed that the Recommendations should generally be applied to High-Rise Buildings of more than 7 or 8 storeys and Iconic Buildings of more than 2 storeys. This is merely good fire engineering practice.
There are valuable lessons, from the NIST Reports, to be applied to the Fire Engineering Design of ALL buildings. This is demonstrated in the Lund Presentation … and, for any ‘Doubting Thomas’ out there, the collapse of WTC Building 7 makes this absolutely obvious.
For a more detailed discussion about the WTC 9-11 Incident and to download the 2005 & 2008 NIST Reports, please visit this Page on our Support WebSite …
http://www.sustainable-design.ie/fire/structdesfire.htm
Extensive content relating to other key words and phrases in the Lund Presentation can be found elsewhere on the Site.
Importance of the CIB W14 Lund Meeting …
The discussion which followed my Lund Presentation was lively and very interesting. This gave me an opportunity, throughout the rest of the meeting, to tweak the Proposed Future Work Programme of CIB W14 towards a more substantive consideration of the Recommendations from the 2 NIST Reports and the Continuing WTC Health Monitoring Studies.
Reluctantly … I will be the Project Leader for an International Team which will examine Fire-Induced Progressive Collapse over the next three years.
I will also be a Member of another Team which will examine Human Behaviour in Fire for a similar period. At the meeting, I indicated that I will be concentrating on Fire Evacuation for People with Activity Limitations (2001 WHO ICF). ‘People with Activity Limitations’ is translated into French as ‘Personnes à Performances Réduites’.
Another Page on CIB W14 : Fire Engineering will soon be added to this Technical Blog.
‘Feeling’ the Violent Earthquake in Abruzzo, Italy ?!?
Exactly a week ago … in the early hours of Monday morning (03:32 hrs local time), 6th April 2009, a violent earthquake hit the central Italian Region of Abruzzo. The quake had a ‘magnitude’ of 6.3 on the Richter Scale … a scale developed by Charles Richter (1900-1985) during the last century, in collaboration with Beno Gutenberg (1889-1960).
The high numbers of fatalities and people injured continue, even at this time of writing … seven days later, to rise and rise. Approaching 60,000 people have been left homeless. It will take many, many years to restore buildings … and much longer than that to restore the delicate social fabric of local communities.
It is a remarkable joy to experience the culture, and live among the people of one such small community in the centre of Italy … Amandola (≈ 4,500 inhabitants), which is a typical hilltop town located approximately 70 Km north of L’Aquila (≈ 67,000 inhabitants), capital of the Abruzzo Region.

Colour photograph showing the view, taken just a few hours after the Abruzzo Earthquake, looking towards L'Aquila over the snow-capped Sibillini Mountains. Click to enlarge. Photograph taken by CJ Walsh from within the historical centre of Amandola, 70 Km away. 2009-04-06.
Earthquakes between 6.1 and 6.9 on the Richter Scale regularly cause damage in areas up to 100 Kilometres away from the ‘epicentre’ … that point on the earth’s surface located vertically above the place deep within the Earth where the quake originated.
To put local news reports into some context … accurate measurement of dramatically increased levels of natural radon activity in soils, allied with a good understanding of local geology and seismology, can be an important, although not 100% reliable, indicator of what is happening deep underground. Unfortunately, and unlike in Ireland, radon protection of buildings is not taken seriously in Italy … so, not much attention would have been paid to what anybody said about radon activity in the soils around L’Aquila before the ‘big one’ hit !
Tremors from an earthquake, or trembling vibrations, can be felt strongly far away from an epicentre. I know, because I was in Amandola last Monday morning.
To be involved in Earthquake Resisting Design is one thing … I am very comfortable with technical issues, facts, concepts, building products, etc. To become intimate, however, with the ‘reality’ of a mother of an Earthquake is altogether different !
Jerked awake in those early hours … the building was rocking, not just swaying. Before reaching full consciousness … too much had already happened. If the building had collapsed, I would never have known what hit me. But, it didn’t … and there was no internal damage or cracking.
I don’t know why … but, I went back to sleep again.
Just after 08.00 hrs (local time), phone texts began to arrive from Ireland … “was everybody safe ?”. Something ‘big’ must have happened during the night. I rushed to put on the television news … forget about SKY NEWS, CNN, BBC and that miserable, no-good, laughable excuse for an ‘impartial, balanced and fair’ news service FOX NEWS … the best coverage … and continuous coverage … was on the Italian TV Stations.
Tragic scenes … of historical buildings destroyed … expected, because they would not be of modern (reinforced concrete or steel) construction … and, far many more than should be the case, of modern buildings seriously damaged or collapsed like a plate of pancakes … somewhat expected, because of inadequate technical controls over building design and construction in many parts of the country.
[Similar scenes of modern, 'tofu' construction could be witnessed after the Major Earthquakes in Central China, beginning in May 2008.]
Later that morning, I inspected an historical building which I had recently restored … and where I had incorporated earthquake resisting features. Relief, relief, relief … not a single crack.
Travelling back to Rome by car that afternoon, fleets of emergency response vehicles moved swiftly in the opposite direction towards the Earthquake Zone …
Water Lilies & Willow Tree – Monet’s Garden at Giverny
Claude Monet (14 November 1840 – 26 December 1926) devoted the last twenty five years of his life to painting the water lilies which floated on the large pond at the bottom of his garden at Giverny … in Normandy, France. There are approximately 250 ‘Water Lilies’ in this series.

Colour Photograph of 'Water Lilies & Willow Tree' in Claude Monet's Garden at Giverny, Normandy. Click to enlarge. Photograph taken by CJ Walsh. 2004-08-29.
This photograph was taken on 29 August 2004. It shows those same water lilies on the pond, and that same willow tree by the bank. Please enjoy.

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