Department of the Environment Heritage and Local Government (DEHLG)
Hazards in Attic Roof Spaces – A Strong Dose of ‘Reality’ !
It’s all happening here ! From trawling the depths of European Union (EU) Legislation in my last Post … to the heights of Attic Roof Spaces in Ireland … what a magnificent contrast !!
This Post has nothing to do with this law, or that law … or the proper technical control of these sorts of troubling situations. It has everything to do with a strong dose of ‘Reality’ … and the typical sorts of Serious Hazards which lurk quietly, unannounced and generally unheeded in most houses … houses which are occupied by ordinary, average people.
The following photographs could have been taken in almost any house, anywhere in the country ! These particular photographs, however, were taken during a House Inspection for a good friend, somewhere in County Wicklow, during May 2010 …
Colour photograph showing the typical clutter which can accumulate, over time, in an Attic Roof Space. Wait and see, however, what else is happening underneath and around this clutter. Smoke Detectors should always be fitted in these Spaces as a matter of routine. Also ... notice that this is a trussed timber roof. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
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Colour photograph showing fire scorched thermal insulation. Careless Hot Works are a major cause of fires in ALL building types! Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
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Colour photograph showing that there is NO fire separation between this house and the neighbouring house at the junction between the party wall and the roof covering. And ... once fire enters this Attic Roof Space, those thin metal connecting plates in the roof trusses will rapidly lose strength, and the entire roof will then collapse. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
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Colour photograph showing a very badly constructed party wall ... see the many gaps in the joints between the concrete blocks. Just because a wall is made of masonry ... do not, for a single moment, assume that it is either smoke resisting or sound resisting. Also ... notice the sloppy DIY electrics. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
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Colour photograph showing, after I had pulled back a portion of thermal insulation, where the insulation had completely covered a downlighter. In other parts of this Attic Roof Space chipboard, to hold all of the clutter, covers the transformers as well. Downlighters need direct ventilation to facilitate the escape of heat. Also ... note the trap doorset is not fire and smoke resisting. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
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Colour photograph showing thermal insulation packed tightly into the roof eaves ... choking off essential ventilation pathways. Thermal insulation was also placed under the water storage tanks ... exposing them to freezing external conditions during cold winter nights. Thick, multi-layered thermal insulation will also conceal the bottom horizontal members in all types of timber roof construction ... expect more fall accidents through ceilings in the future! Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
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There are simple Design and Construction Solutions to all of these problems … and Competent, Independent Technical Control over the works being carried out is absolutely essential.
BUT … Dysfunctional Government Departments and State Agencies are still … to this day … directly sponsoring and knowingly contributing to these hazardous situations in our homes !
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Dublin IFE Fire Conference – Sustainable Fire Engineering !
Nothing less than a complete Paradigm Shift to Sustainable Fire Engineering is now needed … because it is Necessary … because it is Inevitable … because it is The Future !!!
This process will not proceed, however, unless the International Fire Science & Engineering Community begins to communicate and engage, meaningfully, with the Mainstream Construction Sector … where this process is already well advanced.
One Organization in our community has recently decided to bite the bullet … CIB (International Council for Research & Innovation in Building & Construction) … where Working Commission 14 (W14) – ‘Fire Safety’ … agreed, at a meeting in Zurich, to significantly expand and elaborate its own Scope … please note the keywords in bold text …
A CIB Working Commission … W14 is an international, multi-stakeholder, trans-disciplinary, pre-normalization forum for discussion, and action, on research and innovation in Fire Science and Engineering for the design, construction and operation of a Safe and Sustainable Built Environment.
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Colour image showing the Title Page of CJ Walsh's Presentation at the Institution of Fire Engineers (Ireland Branch) Annual Fire Conference ... which will be held on Wednesday, 20th October 2010, in Dublin. Click to enlarge.
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This will be my important message on Wednesday next, 20th October 2010, when I address the Institution of Fire Engineers (Ireland Branch) Annual Fire Conference … which will be held in the Dublin Fire Brigade Training Centre, Marino, Dublin 1 … beginning at 09.30 hrs in the morning.
Institution of Fire Engineers (Ireland Branch)
2010 IFE Annual Fire Conference Brochure
Click the Link Above to read and/or download PDF File (326kb)
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Three Powerful Pulling Forces for Change … or should I say Dragging Forces, with a lot of kicking and screaming involved (!) … will have a direct impact …
1. Sustainable Design
The interior view shown below is not that of a Sustainable Building … but of a Modern Architectural Icon, designed by the Master Architect Mies van der Rohe towards the end of the 1920′s … way back in the last century ! Two innovative architectural concepts are elegantly illustrated in the photograph …
- Open Planning – one space ‘flows’ into the next without interruption by a physical barrier … drawing the eye and encouraging movement. In this particular building … a building of architectural, cultural and historical importance … any attempt to impose ‘fire compartmentation’ on the layout would be utterly ridiculous !
- Separation of Building Structure & Fabric – notice the column in the foreground. This is quite unlike the massive form of building construction in the past !
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Colour photograph showing an Interior View of the Barcelona Pavilion, designed by the German Architect Ludwig Mies van der Rohe in 1929. Photograph taken by CJ Walsh. 2009-03-20. Click to enlarge.
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Fire Engineering is still trying to grapple … unsuccessfully … with innovative approaches, dating from the early part of the 20th Century, to Architectural Design. In the 21st Century, Sustainable Design – not Green Design – involves a far more radical approach to Design, the use of Building Materials, and Construction. In the face of this much greater challenge, Fire Engineering must begin to respond effectively … with creativity and imagination. There is no other alternative !
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2. Cul-de-Sac of Current Fire Engineering
Working in Building Control at the time … I encountered the Typical Building Detail shown below in an early 1990′s Dublin Hotel Extension Project … comprising a 10 metre span steel beam … with non-loadbearing steel stud partitioning beneath, separating a corridor from bedrooms … each with 1 Hour’s Fire Resistance. During a fire and long before the period of 1 Hour has elapsed … that steel beam will have deflected by a considerable dimension. What happens, then, to the non-loadbearing steel stud partition, below, and its fire resistance performance ??? This makes no sense.
Does current Fire Engineering have a robust rational and empirical basis … or is it just one remove from Voodoo and Witchcraft ??
Black and white 'concept' drawing, with a small touch of colour, showing a typical detail in an early 1990's Dublin Hotel Extension Project ... of a 10 metre span steel beam ... with non-loadbearing steel stud partitioning beneath, separating a corridor from bedrooms ... each with 1 hour's fire resistance ?!? Drawn by CJ Walsh.
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3. NIST(USA) Recommendations on the 9-11 WTC Building Collapses
Determined resistance by Vested Interests … a Lack of Institutional Capacity, i.e. failure to be able to properly anticipate, or to be adequately prepared, and/or to respond effectively and in a timely manner to major fire incidents … and a small element of the ‘Issue Attention Cycle’, where considerable investment in time and resources were necessary to make real progress on the issues thrown up by 9-11 but, unfortunately, governmental and public attention soon waned and dissipated … shifting to new problems, e.g. the Illegal Iraq ‘Crusade’ … have all contributed to a situation where there has been little in the way of substantive implementation of the Recommendations contained in the 2005 and 2008 NIST(USA) Reports on the 9-11 WTC Buildings 1, 2 & 7 Collapses … in the United States of America, Europe … or anywhere else.
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Colour photograph of the World Trade Center Complex in New York, taken at the time of the 2nd Plane Impact during the morning of Tuesday, 11th September 2001. Click to enlarge.
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That is not our approach, here, at FireOx International – the Fire Engineering Division of Sustainable Design International Ltd. Instead, we have decided to present all of the NIST Recommendations … to our readers … in a Series of Posts on this Technical Blog.
Sustainable Fire Engineering HAS a robust rational and empirical basis !
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Institutional Failure Increasing European Biodiversity Losses ?
Our Ultimate Goal … as Human Beings … must be to arrive, as quickly as practicable, at a dynamic and harmonious balance between a Sustainable Human Environment and a flourishing, not just a surviving, Natural Environment … with the Overall Aim of achieving Social Wellbeing for All.
Note: Human Environment … Anywhere there is, or has been, an intrusion by a human being in the natural environment.
Note: Social Wellbeing … A general condition – in a community, society or culture – of health, creativity, responsible fulfilment, and sustainable development.
Simply stated … Biodiversity is Critical for the Good Health of the Natural Environment ! And yes … the Natural Environment is a Living System … and we must become comfortable when using such terms as ‘health’, ‘injury’ or ‘harm’ in relation to its condition. Or, should I say ‘her’ condition ??
Furthermore … a Flourishing Natural Environment is an essential foundation for Biodiversity within a Sustainable Built Environment.
Note: Built Environment … Anywhere there is, or has been, a man-made or wrought (worked) intervention by humans in the natural environment, e.g. cities, towns, villages, rural settlements, roads, bridges, tunnels, transport systems, service utilities, and cultivated lands, lakes, rivers, coasts, seas, etc. … including the virtual environment.
[A Short Digression: One important point needs immediate and unequivocal clarification ... it is only in the context of Biodiversity within the Built Environment can there be any consideration or discussion about the Sustainable Use/Exploitation of that Biodiversity !]
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Shamefully … as Human Beings … we have made a terrible, terrible mess of Our Planet. And it continues … and continues …
Initiated at the time of the Deepwater Horizon Offshore Drilling Rig Explosion and Fire, on 20th April 2010 … this summer’s BP Oil Spill in the Gulf of Mexico … an unprecedented Local Environmental, Social and Economic Tragedy and a Regional Disaster … unfolded very quickly and very prominently in front of our eyes. It was a long time, however, before the full nature and extent of this catastrophic incident was revealed.
Excluding the issues of Public Relations Spin, Withholding and/or Concealment of Vital Information, Individual Incompetence, and Lies … Institutional Failure (or, to put it another way, Lack of Institutional Capacity) alone … i.e. failure to properly anticipate, or to be adequately prepared, and/or to respond effectively and in a timely manner … added to, and magnified, the scale of this disaster.
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On Wednesday, 14 July 2010, the following brief overview describes the United States Disaster Response … my sincere apologies for reproducing the quaint, but prehistoric, Imperial Units of Measure …
Disaster Response Vessels
- Vessels of Opportunity: 2,754
- Barges: more than 540
- Skimmers: more than 580
- Other Vessels: more than 3,000
- Total Active Response Vessels: more than 6,870
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- Aircraft: 119
Boom Data
- Boom deployed: more than 3.27 million feet
- Boom available: more than 855,000 feet
- Total Boom: more than 4.12 million feet
Oil Recovered
- Oily Water Recovered: nearly 32.9 million gallons
- Amount Estimated Burned: nearly 10.97 million gallons
- Oil Captured (CAP) over last 24hrs: more than 539,000 gallons
Oil Dispersants
- Surface dispersant used: more than 1.07 million gallons
- Sub-sea dispersant used: more than 762,000 gallons
- Total Dispersant Used: more than 1.83 million gallons
Personnel Involved
- Overall Personnel Responding: more than 44,000 personnel
[Source ... http://www.restorethegulf.gov/release/2010/07/15/operations-and-ongoing-response-july-15-2010]
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United States National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling
Staff Working Paper No.2 – 6 October 2010
Decision-Making within the Unified Command
Click the Link Above to read and/or download PDF File (276kb)
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IN EUROPE … during this International Year of Biodiversity … a Major and Widespread Regional Disaster is unfolding quietly, slowly … hidden from the view of the general European public … and in relation to which important lessons must be learned from the Gulf of Mexico Oil Disaster. Please examine closely that U.S. National Commission’s Staff Working Paper No.2 above.
On 4th October 2010 … the European Environment Agency (EEA) published Report No.5 : ‘Assessing Biodiversity in Europe’ … which clearly stated (in the final paragraph of the final chapter … and then, only when quoting from another document !) …
‘ a large proportion of European species and habitats are either facing extinction, have an unfavourable conservation status, or their status is unknown.’
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THE QUESTION which must be asked is … whether there is yet proper … or even sufficient … Institutional Capacity at European Union and EU Member State levels to implement Any European Biodiversity Strategy … with the clearly specified target of protecting, conserving and nurturing Biological Diversity in Europe ???
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Does the following cautiously worded text convince you ? Not me, I’m afraid !
EEA Technical Report No.5 / 2010 – Chapter 4 – ‘Conclusions, Way Forward & Knowledge Gaps’
European Biodiversity has declined dramatically in the last two centuries, with the conversion of natural habitats to meet growing demands for food, energy and infrastructure. Although the pace of change has varied across the region and has generally slowed considerably in the last couple of decades, agricultural land use now accounts for almost half of the European terrestrial area.
In coastal and marine areas, industrial fishery operations have had similarly large impacts, affecting both fish populations and habitats throughout European coastal and marine waters. Nearly half of assessed fish stocks in Europe fall outside safe biological limits. The majority of biodiversity in Europe now exists within a mosaic of heavily managed land and seascapes, and is to a large degree linked to agricultural, forestry and fishery practices across the continent.
In recent decades, growing awareness of biodiversity decline has led to improved commitments, policies and practices for the conservation and sustainable use of biodiversity throughout much of Europe. Biodiversity is now higher on the political agenda in Europe than ever before. Significant targeted responses have been made by public, civil society and private institutions to restore habitats, protect threatened species and reduce the main threats to biodiversity in Europe.
As a result of the policies adopted and implemented at international and European scales, including the Birds, Habitats, and Water Framework Directives, there are indications that some aspects of biodiversity are improving in status in parts of Europe. There have been significant increases in forest cover in the last two decades across northern Europe and the status of many waterways has improved across Europe as a result of reduced industrial and agricultural pollution in many countries. Recovery plans have been documented and are being implemented for many of Europe’s threatened species, with some successes.
While ambitious targets are being set in Europe to halt biodiversity loss and some progress is being made, many threats remain and new ones are growing. This erodes the ability of ecosystems to provide services to people in Europe and beyond.
Threats to Europe’s biodiversity include habitat loss and degradation, unsustainable harvesting, establishment and spread of invasive alien species, pollution from agricultural runoff in many countries, unsustainable forest and agriculture management, increasing water abstraction and use, and increasing climatic change impacts, especially in southern and northern Europe, and in mountainous areas across the region. The loss of wetland and dryland habitats also continues.
Future Progress in addressing these threats and conserving Europe’s Remaining Biodiversity will depend on success in Four Key Areas:
1. Enhanced Implementation Of Measures Targeted At Biodiversity Conservation. There has been progress in protecting and restoring threatened species and habitats across much of Europe, and protected areas and sustainable farmland and forestry management practices have grown steadily. However, there remains considerable opportunity to scale up such practices across the region, including coastal and marine areas. Such direct efforts for biodiversity conservation are a cornerstone of conservation. They are essential to manage the most important threats and conserve the most threatened biodiversity. However, alone they are insufficient to address biodiversity loss in the medium and long term because many of the direct drivers, and all of the indirect drivers of biodiversity loss, emanate from other sectors.
2. Policy Coherence On Biodiversity Is Required With Other Sectors. In order to conserve and sustainably use biodiversity, policies in other sectors that have an impact on or depend on biodiversity need to be supportive. These include those on trade, agriculture, fisheries, planning, transport, health, tourism, and the financial sector, including insurance. In many EU countries, considerable funding for managing biodiversity in landscapes is obtained from the Common Agricultural Policy (CAP). Mainstreaming biodiversity into these areas – in both the public and private sectors – is essential for an integrated approach to biodiversity conservation. Successful mainstreaming will require all sectors to recognise the value of biodiversity. Recent efforts to ascribe accurate economic values to biodiversity and ecosystem services, for example ‘The Economics of Ecosystems and Biodiversity’ (TEEB, 2010), provide a basis for mainstreaming.
3. A More Integrated Approach Across Sectors And Administrative Boundaries, At Landscape And Seascape Scales. This entails applying the ecosystem approach more widely, and requires co-operation across sectors for successful implementation. The present report shows that management of some habitat types, such as forestry and freshwater systems, is already starting to apply such approaches. Others, such as marine habitats, mountains and agricultural land, have not yet been adjusted sufficiently. Integrating protected areas, ecological networks, connectivity areas, production and urban landscapes into multifunctional land-use planning at a regional scale will be an essential element of a successful European conservation strategy. Likewise at watershed and landscape scales, the integration of biodiversity and natural resources management, including that of water, will require dialogue and agreement between the multiple stakeholders using, depending on, and managing such resources.
4. Public Awareness Of The Relevance Of Biodiversity To The Lives Of European Citizens, And The Consequences Of Biodiversity Loss At Local, European And Global Scales, Needs To Be Raised. Significant efforts are therefore required on communication, education and public awareness, to complement the policy framework and to encourage both individual action for biodiversity conservation, and a supportive public opinion for changes in policy and practice.
This report shows that, particularly regarding forest habitats, public awareness of the value of sustainable practices and recycling is increasing. This can be enhanced by publicising how more sustainable practices can benefit both society and the ecosystems themselves.
Despite being the region with the longest and broadest biodiversity knowledge base, key knowledge gaps remain across Europe. Filling such gaps would support action and policies across the four key areas.
Knowledge gaps exist in individual elements of biodiversity. Little is known, for example, about many aquatic systems (and especially floodplains and deltas), genetic diversity beyond the agricultural sector, and for many taxa at the species level. Considerable further work is required to assess the status of plants, invertebrates and fungi, and to assess trends in species status. A global base of species level assessments (or ‘Barometer of Life’) would cost some €45 million (Euros), according to recent estimates (Stuart et al., 2010).
My Note: Taxon (plural Taxa) … Any unit used in the science of Biological Classification, or Taxonomy. Taxa are arranged in a hierarchy from kingdom to sub-species, a given taxon ordinarily including several taxa of lower rank. In the classification of protists, plants and animals, certain taxonomic categories are universally recognized; in descending order, these are kingdom, phylum (in plants, division), class, order, family, genus, species, and sub-species, or race.
In addition to knowledge of specific elements of biodiversity, interdisciplinary knowledge gaps are particularly apparent, with little in the way of accumulated knowledge on the interlinkages between biodiversity, ecosystem services and human wellbeing. Recent efforts to link biodiversity science with economics have been particularly promising but further interdisciplinary research and assessment would support strengthened decision-making and policymaking processes on European biodiversity in the 21st century.
Key Gaps in Knowledge that emerge from this report are as follows …
- Data Availability: Data beyond EU-27 Member States are often limited, especially European-level information on biodiversity (species, communities and genetic stock). Generally, data for marine species and habitats are much scarcer than for terrestrial ecosystems, and across Europe some important ecosystem types (e.g. marine and coastal) are among the least studied. Data are often lacking at relevant scales, e.g. for key environmental drivers or habitat change. This information would help set solid and relevant targets and continually improve sustainable management schemes.
- Climate Change Adaptation Strategies: Information on adaptation measures and strategies is often insufficient for many European ecosystems to counteract adverse climate change impacts and maintain ecosystem goods and services (e.g. FAO, 2009). While climate change considerations have largely driven the debate on adaptive capacity and vulnerability, there is now increased recognition of the multidimensional nature of drivers of change, responses and feedback mechanisms (e.g. CDE, 2009).
- Ecosystem Services: Enhanced information on environmental, economic and social benefits of the ecosystem services supplied by biodiversity is lacking to inform sustainable management of ecosystems and raise public awareness of biodiversity’s value and the link to livelihoods. The value of non-marketed goods and services are an important element in this.
- Optimal Land-Use Strategies: It is important to finding the optimal mix of protected and productive areas, whether used for intensive agriculture or biomass for energy. More detailed data and analysis are needed to assess the extent and consequences of losing natural habitats through land conversion for increased biomass, e.g. biofuel feedstock production (FAO, 2008). Ecosystem approaches are also particularly well suited for addressing competing land-use issues in a systematic and holistic framework, even in the absence of economic valuations, and they have considerable potential as an integrated management tool (Hicks et al., 2008).
- Sustainable Management Indicators: More knowledge on sustainable management indicators is required along the lines of the pan-European indicators of sustainable forest management.
- Green Infrastructure: More information is required on the potential benefits of a green infrastructure approach to facilitate land development and land conservation together in a way that is consistent with existing natural features to deliver multiple benefits to people and biodiversity.
Recognising the urgent need to address these issues and reverse the trends of biodiversity loss and ecosystem degradation, the Environment Council adopted the 2020 Headline Target on 15 March 2010 and the European Council endorsed the Long-Term Biodiversity Vision on 26 March 2010. These ambitious initiatives will underpin the new EU Biodiversity Strategy to be finalised by the end of 2010. In its conclusions, the European Council specified that the strategy to address biodiversity loss and ecosystem degradation should set a clear baseline outlining the criteria against which achievements are to be assessed.
EEA developed the EU 2010 Biodiversity Baseline (EEA, 2010) to respond to this need. It offers a comprehensive snapshot of the current state of biodiversity. It thereby supports the EU in developing the post 2010 sub-targets as part of the biodiversity strategy and provides factual data for measuring and monitoring progress in the EU from 2011 to 2020. This new information tool demonstrates that a large proportion of European species and habitats are either facing extinction, have an unfavourable conservation status or their status is unknown. It highlights the urgent need for conservation actions and intensified efforts.
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In Ireland … am I convinced that the New National Biodiversity Plan 2010-2015 (draft for public consultation, dated 1st September 2010) will turn out to be anything more than just another slick looking public relations document issued by our one and only Department of the Environment, Heritage & Local Government (DEHLG) ? I’ll give you one guess what my answer is !!!
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How ‘Sustainable’ are Built Environment Adaptation Projects ?
2010-04-01: The Inter-Basin Water Transfer Project from Lough Ree, on the River Shannon, to Dublin City, in Ireland, has been described as a Pilot Adaptation Project on the United Nations Framework Convention on Climate Change (UNFCCC) WebSite Database relating to the Nairobi Work Programme (2005-2010).
I did not imagine this … please check out the listing, for yourselves, on this WebPage … www.unfccc.int/adaptation/nairobi_work_programme/knowledge_resources_and_publications/items/4555.php?sort=focus_sort&dirc=DESC&seite=1&anf=0&type=®ion=&focus=&means=
Detailed information concerning the Project can be accessed and downloaded at this Irish Address: www.watersupplyproject-dublinregion.ie It will cost approximately €600 million (probably much more !) … devour many material resources and have an adverse environmental impact … the objective being to divert water from the Shannon, a large river in the mid-west of the country … to Dublin, the capital city, which is located over 100 kilometres away on the east coast … in order to deal with the expected shortage of water which will be caused, among other relevant factors, by future climate change.
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Colour image showing the many options for a future Dublin Region Water Supply Project ... linking the River Shannon, and its lakes ... to the Capital City, which is over 100 kilometres away on the east coast. Click to enlarge.
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BUT … just how Sustainable is this Climate Change Adaptation Project … if the following other relevant factors are considered ?????
1. Since the 1960′s … a dysfunctional and corrupt Spatial Planning System in the Dublin City Region has actively encouraged an uncontrolled, urban and suburban horizontal sprawl to take place. Today, this pattern of development remains unchecked.
2. At this time, there are still no Residential Water Charges in Dublin. The concept of water conservation is, therefore, almost unknown among householders. National and local politicians are terrified by any prospect of having to vote in favour of imposing these necessary charges.
3. There are enormous un-intended losses, i.e. Leaks, from the public mains potable/drinking water distribution system … approximately 40% even in the good times, and recently, well in excess of 60% following the National Snow Emergency in Ireland.
4. Potable/drinking water supplied to houses in the Dublin City Region is not yet Metered. There is no urgency, therefore, in locating and repairing water leaks which occur between the private property boundary of a house and the house itself.
5. There is no existing legal requirement in Ireland’s National Building Regulations to Harvest Rainwater in any buildings, or on any hard surfaces in the vicinity of those buildings. A current proposal to amend Technical Guidance Document H: ‘Drainage & Waste Water Disposal’ will merely present relevant guidance text to building designers concerning this option.
Furthermore, there is no effective System of Technical Control operated by the Local Authorities in the City Region … to enforce a legal requirement concerning rainwater harvesting … even if such a legal requirement were to be introduced !
6. In 2005-2006, at the height of the Celtic Tiger Economic Boom … the existing Foul and Storm Water Drainage Infrastructure in the City Region was already stretched to keep pace with the ‘wild’ demands for new development land. Detailed information concerning the Greater Dublin Strategic Drainage Study can be accessed and downloaded at this Irish Address: www.dublincity.ie/WaterWasteEnvironment/WasteWater/Drainage/GreaterDublinStrategicDrainageStudy/Pages/RegionalDrainagePolicies-OverallPolicyDocument.aspx
Overloading of the existing drainage systems was evident from a marked deterioration in water quality, increased risks of flooding and pollution, and concerns that the drainage system and sewage treatment plants had insufficient capacity to cater for future development.
7. Sustainability Impact Assessment (SIA) …
‘ a continual evaluation and optimization assessment – informing initial decision-making, or design, and shaping activity/product/service realization, useful life and termination, or final disposal – of the interrelated positive and negative social, economic, environmental, institutional, political and legal impacts on balanced and equitable implementation of Sustainable Human & Social Development ‘
… is not yet a standard procedure, at any level, within national, regional and local Authorities Having Jurisdiction (AHJ’s). If it were, the most glaring flaw in this project would rapidly be identified. There is no comprehension at all, in the minds of Dublin City’s decision-makers, that water is a very valuable, but limited, resource !
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Although today is 1st April 2010 … far too many people in senior policy and decision-making roles are giving solemn, unquestioning consideration to this Project.
To be successful, however, National Adaptation Strategies, Programmes and Projects must be informed, in a meaningful way, by the concept of Sustainable Human and Social Development … and, prior to implementation, must be filtered through the lens of a comprehensive Sustainability Impact Assessment (SIA) !
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POSTSCRIPT
2011-09-29: Relevant extract from the 2010 Annual Report of the Irish Comptroller and Auditor General - Volume 2 …
WATER SERVICES EFFECTIVENESS
22.11 Funding for the provision of infrastructure for the supply of drinking water is provided by the Department of the Environment, Community and Local Government under two programmes. Major water supply schemes are included in the rolling three-year Water Services Investment Programme (WSIP). These schemes focus on the larger concentrations of population in urban areas. Annual Rural Water Programmes (RWP) provide the bulk of funding for the construction of group water schemes and small public schemes in rural areas.
22.12 Over the period 2000-2010, €5.2 Billion of Exchequer resources have been invested in the upgrading and provision of new water services infrastructure, of which €4.2 Billion was spent on WSIP and €0.99 Billion was spent on RWP. Overall expenditure includes investment of over €1 Billion on public water supply and networks and €168 Million on water conservation. [The WSIP expenditure also includes €889 million relating mainly to the group water sector under the rural water programme.] There are two key indicators of the effectiveness of expenditure on water supply and conservation:
- the quality of drinking water;
- the extent to which treated water reaches the consumer.
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Effectiveness of Water Supply System
22.17 Loss of output is a feature of all water distribution systems. Unaccounted for Water (UFW) is a measure that is used to track this loss. It is the difference between ‘net production’ which is the volume of water delivered into a network and ‘consumption’ measured in terms of the volume of water that can be accounted for by legitimate consumption.
22.18 Figure 109 shows UFW as a percentage of the net volume of water supplied for 2008 and 2009. It sets out the national average performance and the range across local authorities. Annex A contains the data on UFW for these two years for all county and city councils.
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Black and white image showing Figure 109: 'Unaccounted for Water (UFW) as a Percentage of Water Supplied, 2008-2009' ... from the 2010 Annual Report of the Irish Comptroller and Auditor General - Volume 2. Click to enlarge.
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Black and white image showing Annex A: 'Unaccounted for Water (UFW) as a Percentage of Total Volume of Water Supplied, 2008 and 2009' ... from the 2010 Annual Report of the Irish Comptroller and Auditor General - Volume 2. Click to enlarge.
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22.19 Overall, the average percentage of UFW was approximately 41.48% in 2009, which showed a marginal increase over 2008 (41.20%). Some 17 of the 34 authorities have seen an improvement in 2009, the most noticeable being a reduction in the percentage of water lost in Monaghan which was down by 27%, Cavan by 18% and Kilkenny by 15%. The other 17 local authorities reported a disimprovement in the amount of UFW for 2009, with Limerick County Council reporting losses of 35%, up from 17% in 2008. Fingal County Council, Limerick City Council, and Dublin City Council reported substantial increased leakage in 2009 over 2008 at 27%, 22% and 20% respectively.
Cost of Unaccounted for Water (UFW)
22.20 The cost of UFW is considerable for local authorities. However, since the LGMSB does not collate information on water production and associated costs the data is not available in the Department of the Environment, Community and Local Government. As a result, it is not possible in this report to provide an up-to-date estimate of the cost of UFW being experienced.
22.21 A value for money examination carried out in the mid-1990’s on water production and distribution showed that the cost per cubic metre of water produced varied between €0.14 to €0.39. The study found that overall water leakage level in the authorities surveyed at that time ranged from 27% to 40% of total water produced.
22.22 The results of the study were based on estimates since none of the authorities that were the subject of the value for money examination had the means to measure accurately the level of overall leakage.
22.23 Based on its results, the examination reported that, for five local authorities reviewed at that time, the estimated annual production cost of the water lost due to leakages was in the order of €3.5 million. Applying the Consumer Price Index to this value brings the cost to approximately €5.3 million in present-day terms.
22.24 As leakage is just one factor contributing to UFW, it appears from the losses now being recorded by local authorities that there has been little, if any, improvement in the situation despite the considerable State investment in water services in the interim.
Views of the Accounting Officer
22.25 The Accounting Officer informed me that under the National Water Conservation Sub-Programme, which commenced in 1996, the National Water Study undertook a comprehensive national water audit of all urban centres with populations exceeding 5,000 to determine the extent of UFW and leakage problems nationally. The National Water Study examined the reasons for UFW and set out recommendations to reduce the levels of UFW.
22.26 Arising from the findings of the National Water Study and pilot water conservation schemes undertaken in the main urban centres of Dublin, Cork, Galway, Waterford and Limerick, water conservation strategies and operational programmes were adopted which have been rolled out nationally since 2003.
22.27 The Dublin Region Water Conservation Programme, which was carried out between 1998 and 2002 as one of the pilot schemes under the National Water Conservation Sub-Programme, reduced regional leakage from 47% to 28%. UFW in the Dublin region now averages 30% which is amongst the lowest in the country.
22.28 Since the commencement of the water conservation sub-programme, substantial investment has been made in the fundamental infrastructure for water management, including the metering of supply input. Also, the methodology has been standardised. Arising from this, the reported figures now have an accuracy that the figures from earlier times could not have had.
22.29 By way of example, the Greater Dublin Water Supply Strategic Study (1996) estimated losses of 44% of total input, of which 39% was allocated to distribution losses and 5% allocated to customer losses. When the metering infrastructure was checked and upgraded during the water conservation project (around 2000), it was found that the original meter readings for flow into supply were incorrect, and that losses were actually higher than originally thought (giving the corrected estimate for that time of 42% distribution losses and 47% in total). Notwithstanding that the Dublin Region bulk metering infrastructure was considered reliable at the time, it was found to have inaccuracies that were subsequently corrected.
22.30 In terms of comparisons, the Accounting Officer pointed out that the Dublin supply is hugely significant, serving approximately one third of the population of the country. Consequently, the Dublin supply region reduction of distribution loss from 42% to 30% currently must reflect positively on the national average (and it is the corrected Dublin Region figure from 1995/96 that is most reliably reflective of the situation at that time).
22.31 A further observation by the Accounting Officer was that without investment the leakage situation will deteriorate as assets age. It follows that a certain level of investment is required even just to maintain the status quo.
22.32 The Accounting Officer stated that, outside of Dublin, most of the investment had been in water management systems, which while they had made a contribution to tackling leakage, were really the platform for the more intensive investment being rolled out for mains rehabilitation in the WSIP 2010-2012. She said that this investment in water management systems had contributed to greater efficiency in the supply system, which had been demonstrated during the two severe winters and flooding in Cork, when authorities had been better able to manage the rationing of supply and restoration of supply than they would have been a decade ago.
22.33 Finally, the Accounting Officer said that the need to focus on water conservation had been demonstrated through the development of service indicators, training in water conservation, development of guidance and work with the County and City Managers Association to streamline the approaches and accelerate work in this area.
CONCLUSION – Effectiveness of Water Supply System
UFW arises from factors such as leakage, poor service connections and metering errors. Average UFW levels in Ireland appear to be at levels twice the OECD average of 20%. While some caution needs to be applied in interpreting the results of a limited examination of water leakage carried out over 15 years ago, present-day losses may be, in many local authorities, as high as those found in the mid-1990’s, notwithstanding an investment of over €1 Billion in water supply and conservation in the last ten years.
In the light of the potential cost of UFW it is necessary that the factors that give rise to UFW be reviewed and strategies and operational programmes to address the underlying issues contributing to the problem be re-evaluated.
.
.
END
The Recent Major Emergency Response Fiascos in Ireland
Unless you have been living, for the past two or three months, in conditions similar to a detainee in the illegally occupied part of Cuba, called Guantánamo Bay … and you have been deprived of almost all sensory perception … you cannot have escaped (!) the fact that we have had a Major National Flood Emergency … followed by a Major National Snow Emergency … followed, again, by a National Flood & Water Emergency. I kid you not !!! But … the emergencies haven’t yet ended. And … it’s not just the politicians … at national and local levels … who should bury their heads in shame.
It has been amply demonstrated that the relevant emergency-related institutions in this country are incompetent, disorganized and dysfunctional. Focus your venomous attentions, as well, on the civil and public servants, administrative and technical staff, and private sector technical consultants who occupy space in these institutions.
Did you know that we actually have a National Directorate for Fire & Emergency Management (NDFEM), which is located deep within the Custom House … in the centre of Dublin City. According to the NDFEM, a Major Emergency is …
‘ An incident which, usually with little or no warning, causes or threatens death or injury, serious disruption of essential services or damage to property, the environment or infrastructure … beyond the normal capabilities of the principal emergency services (An Garda Síochána, the Ambulance Service and the Fire Service) in the area in which the event occurs.’
Pages dedicated to NDFEM can be found on the Department of the Environment, Heritage & Local Government (DEHLG) WebSite … www.environ.ie
From the DEHLG HomePage, follow the link to the National Directorate for Fire & Emergency Management.
Please read … without laughing, crying, screaming out loud in utter frustration, or any combination thereof … about the NDFEM’s Mandate and Structure here … www.environ.ie/en/LocalGovernment/NationalDirectorateforFireandEmergencyManagement
Then … and only if you are brave enough … check out the Bozos, Wasters and Lúdramáns who sit on the NDFEM’s Management Board here … www.environ.ie/en/LocalGovernment/NationalDirectorateforFireandEmergencyManagement/ManagementBoard … and the NDFEM’s Consultative Committee here … www.environ.ie/en/LocalGovernment/NationalDirectorateforFireandEmergencyManagement/ConsultativeCommittee
Prize specimens ! At least we can get rid of politicians at the next elections !!
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END
Older People in Emergencies – Action & Policy Development (II)
In 2008, the World Health Organization (WHO) Report: ‘Older People in Emergencies – Considerations for Action & Policy Development’ was published.
The following are short extracts from that Report …
Older People
Until recently, older peoples’ needs in disasters and conflicts were addressed only by broader adult health and humanitarian programmes. This has changed, as several recent emergencies highlighted this population’s vulnerabilities. Of the 14,800 deaths in France during the 2003 heat wave, 70% were people over 75 years of age. Of the estimated 1,330 people who died in the wake of Hurricane Katrina, most were older people. In Louisiana, 71% of those who died were older than 60 years; 47% of this group were over 77 years old. Worldwide, the United Nations High Commissioner for Refugees (UNHCR) has estimated that older people make up 8.5% of the overall refugee population, and in some cases comprise more than 30% of caseloads. In 2005, approximately 2.7 million people over the age of 60 were living as refugees or internally displaced persons.
Globally, the proportion of older people is growing faster than any other age group. In 2000 one in ten, or about 600 million, people were 60 years of age or older. By 2025, this figure is expected to reach 1.2 billion people, and in 2050 around 1.9 billion. In developing countries, where 80% of older people live, the proportion of those over 60 years old in 2025 will increase from 7% to 12%. Moreover, life expectancy at birth has increased globally from 48 years in 1955 to 65 in 1995, and is projected to reach 73 in 2025. By 2050, people over 80 years old are expected to account for 4% of the world’s population, up from 1% today.
Disability & Older People
Worldwide, it is estimated that more than 80% of the disabled population lives in developing countries, where the prevalence of disability is approximately 20%. That rate is expected to increase dramatically as populations age. By 2050 in India, the incidence of disability is expected to jump by 120%, in China by 70% and in sub-Saharan Africa by 257%.
Emergency Planners must consider these trends, because poor health and reduced mobility increase the risk of serious injury and illness in disasters. Older people have sustained more injuries in disasters than other groups because of functional limitations such as poor balance, muscle weakness and exhaustion. Older people have higher rates of coronary heart disease, diabetes, stroke, cancer, respiratory diseases and rheumatism. A study in China found that 74% of those over 80 years old had chronic diseases, 1.5% were physically disabled, and 3.46% had Alzheimer’s disease. In Iraq, more than half of 340 older people surveyed by HelpAge International had chronic joint and bone problems, hypertension, heart problems, diabetes and reduced eyesight and hearing. In West Darfur, Sudan, 34% of surveyed refugees 50 years of age and over were disabled, 27% could not move without help and 19% had severely impaired vision; while 61% reported chronic diseases that required specialized treatment and/or medicines that were not available.
Objective 1: Increase Visibility and Raise Awareness among Health Agencies and Humanitarian Organizations about Older Peoples’ Needs and Priorities in Emergencies.
- Mainstream and integrate issues related to older people and emergencies into existing policies and guidelines (i.e. emergency medicine, nutrition, protection, gender-based violence, participatory assessments and programming). Include plans for older people in national policy and guideline documents.
- Highlight the need to assist and protect older people as well as their capacities and contributions in rebuilding affected communities.
- Develop inter-agency efforts to identify gaps, develop practice guidelines and provide training and education.
- Promote better practice policies and documents among all stakeholders.
- Collaborate with funders to increase humanitarian assistance to older people based on needs assessments and reflect these in funding proposal criteria.
- Involve older people in developing emergency management activities to increase their visibility and ensure their needs are taken into account, for example, in shelter plans and locations.
Objective 2: Develop Essential Medical and Health Resources for Older People in Emergency Practices.
- Identify and include essential medicines for older people in emergency kits. Include medicines for chronic diseases and other illnesses common among this social group.
- Develop disability aid packages with equipment such as eyeglasses and walking sticks.
- Develop education modules for health professionals on diseases common among older people, including HIV/AIDS.
- Develop and disseminate guidelines for geriatric medicine in emergencies and humanitarian crises.
- Within the health care system, ensure that conditions and needs common to older people are integrated into patient triage, clinical evaluation, treatment, the emergency medical response system and access to specialty care.
- Ensure that nutritional guidelines for food distribution suitable for older people are integrated into health planning and response plans.
- Ensure local development of guidelines for feeding older people, using locally available foods to the extent this is possible where populations depend on external food aid.
- Implement gender-based analyses in planning and programme design to account for differences between older men and women in terms of both health needs and access issues.
Objective 3: Develop Emergency Management Policies and Tools to Address Older Peoples’ Health-Related Vulnerabilities.
- Integrate older peoples’ health needs and related issues into assessment tools and practices.
- Develop community-based tools using disaggregated data to identify vulnerable older people. Include formats to identify chronic health conditions, disabilities and nutritional needs.
- Develop procedures to identify hidden and stay-behind older people.
- Develop standardized tools to assess support needs of older people, including inter-generational and community care options.
- Develop age-friendly standards and guidelines so that service and care environments are accessible to older people with disabilities.
- In collaboration with older people, their families and communities, develop personal and household preparedness kits in areas of predictable disasters.
- Collaborate with communities in identifying and implementing community-based home care and support strategies which may reduce older peoples’ isolation and vulnerability during crises.
- Develop guidelines and evacuation plans that include mechanisms to identify and transport frail, disabled and older people with special medical conditions. Identify procedures to ensure adequate care and treatment as necessary.
- Develop guidelines to ensure safe and adequate treatment of older people in evacuation centres and refugee camps.
- Ensure that health facilities have feasible plans to care for older people during disasters and humanitarian crises.
- Develop monitoring and evaluation tools to measure the performance of health care services and humanitarian interventions targeting older people. These measures should be integrated into existing monitoring and evaluation procedures where possible.
Objective 4: Ensure that Older People are Aware of and Have Access to Essential Emergency Health Care Services.
- Use established assessment tools to identify and locate frail and disabled older people and those with chronic diseases and special medical conditions, as well as older caretakers of orphaned children.
- Ensure that assessments are participatory and target all older populations. Assessments should include information on health conditions, social support needs, caretaking responsibilities and available means to meet basic living needs, including access to food and health services, treatment and medicines.
- Ensure that assessments are coordinated across primary health care, rehabilitation, long term care and social services to meet the needs of older people.
- Implement outreach services and referral mechanisms to identify and ensure care for hidden or stay-behind older people.
- Coordinate primary health care, rehabilitation, long-term care and social services to establish system referral mechanisms that older clients may require.
- Assess and organize training for health staff to ensure knowledge of geriatric nutritional, health and medical care needs.
- Establish information programmes to educate older people, families and caregivers about nutritional needs, medical conditions and health care options.
- Use disaggregated data to assess services by age and gender.
Objective 5: Provide Age-Sensitive and Appropriate Health and Humanitarian Services to Maintain Older Peoples’ Health.
- Ensure that equitable access to shelter, clothing, food and sanitation prevent deterioration of health through integrated individual assessments and referrals to health and humanitarian agencies.
- Ensure that age-friendly practices are used to promote services to older people with disabilities.
- Provide access to appropriate health care, including medicines for chronic diseases and disability/restorative aids.
- Collaborate with communities in identifying community-based home care and support options for frail and disabled older people.
- When appropriate and feasible, develop mobile clinics to extend health services to older people living in remote locations.
- Implement mechanisms to assess nutritional balance and ensure access to supplementary food programmes when appropriate, taking into account that many older people also care for children. Provide education on food preparation using supplementary or locally available foods.
- Ensure that protection needs of older people are integrated into programming (e.g. social welfare or community services) to identify persons at risk and prevent abuse and exploitation.
- Undertake monitoring to assess continuing effectiveness of services to older people.
- Use disaggregated data to assess efficiency of implemented activities by age and gender.
Objective 6: Promote Cross-Sectoral Planning and Co-Ordination to Raise Awareness of Older Peoples’ Needs in Crises and Reduce Their Risk of Marginalization and Deteriorating Health in Emergencies.
- Raise awareness among agencies and organizations concerning physical and health issues specific to older people and of ways to adapt basic need support to their requirements (e.g. supplementary food rations, livelihood needs and impacts of protection issues on older peoples’ physical and psychological health).
- Where possible, include older people in planning and programming committees to increase their visibility and ensure their needs and priorities are integrated.
- In coordination with appropriate partners, establish community self-help groups to facilitate community care for more vulnerable older people.
- Recognize self-sufficiency as key to maintaining health and encourage the inclusion of older people in training programmes, income-generation schemes, and community development projects.
- Establish older peoples’ committees to facilitate self-advocacy and communication with authorities and ministries of health to increase access to existing services and entitlements.
Objective 7: Build Institutional Capacity and Commitment towards Ensuring the Health and Safety of Older People in Emergencies.
- Integrate cross-cutting health emergency management issues into global/regional/country strategic plans.
- Promote inter-agency and cross-sectoral consultation on cross-cutting policy and programming issues to build consensus, commitment and capacity to respond to older peoples’ needs in disasters and humanitarian crises.
- Collaborate with ministries of health to establish mandates and legislation ensuring the provision of care to older people; apply a human rights framework to these issues.
- Collaborate with ministries of health to develop options to increase older peoples’ access to affordable health care services, including the implementation of subsidized medical and medicine programmes.
- Advocate for enhanced funding and humanitarian assistance to older people in emergencies and conflicts. Encourage funding agencies to recognize older people as a priority.
- Develop frameworks to promote participatory, transparent and accountable processes to advance the needs of older people.
- Develop sustainable mechanisms to maintain advocacy and consultation of older people within the health care-system. Establish and involve advocacy committees in the planning, implementation and evaluation of emergency management practices when appropriate, for example regarding the design of community shelters that may be accessed by older disabled people.
Objective 8: Strengthen the Capacity of Ministries of Health and Health Care Systems to Meet the Needs of Older People in Emergencies.
- As required, integrate the medical and nutritional needs of older people into local public health and emergency preparedness and response strategies.
- Develop strategies to ensure that existing health care systems develop capacity (infrastructure and knowledge) to meet the increasing proportion of older people who will be impacted by disasters in the future, taking into account medical, disability and mental health needs, including dementia and Alzheimer’s disease.
- Collaborate with communities in identifying community-based home care and support strategies for older people as an option to reduce older peoples’ isolation and vulnerability to disasters.
- Collaborate with communities to develop and maintain disaster reduction committees. Assist in the implementation of strategies to strengthen community support to older people and reduce their levels of risk during disasters (e.g. development of community emergency response teams or mutual assistance groups among more vulnerable older people).
- Integrate older peoples’ needs into exercise designs and facilitate the dissemination of lessons learned.
- Develop performance frameworks and monitoring mechanisms to assess medical response systems and older peoples’ access to specialty care in emergencies.
Objective 9: Develop Mechanisms to Ensure Continuing Development and Exchange of Expertise as these Relate to Older People in Emergencies.
- Develop and provide ongoing training and education to staff on the needs and priorities of older people, including responsibility to include this population in planning and policy development.
- Integrate issues related to older people in emergencies into relevant university curricula.
- Undertake comparative research to assess the health status (including access to assistance) of older people in emergencies vis-à-vis other age groups.
- Undertake research to address demographic shifts and the increasing proportion of older people in disasters as this relates to health care and infrastructure/facility development.
- Ensure emergency preparedness and response considerations are integrated into relevant services and institutions (e.g. facilities caring for frail and disabled older people are required to develop and practice evacuation and emergency care plans).
Objective 10: Promote Active Ageing as a Strategy to Reduce Vulnerability and Develop Resiliency to Disasters.
- Promote a wider understanding among ministries of health and humanitarian organizations of the economic and social factors contributing to the vulnerability of older people, including issues related to livelihoods, inter-generational dependence and social pension.
- Develop policies that recognize active ageing and resiliency as facilitating older peoples’ capacity to prepare for, cope with and respond to the affects of disasters and conflicts.
- Include a life course perspective that recognizes health promotion and prevention of disease and disability.
- Support cross-sectoral forums and activities which link the risks of older people in emergencies to frameworks for livelihoods, protection and gender-based equality, health promotion and social pension.
- Collaborate with relevant organizations to mainstream the health needs of older people into existing humanitarian programmes addressing shelter, nutrition, livelihoods, protection and gender-based violence.
- Develop information campaigns and encourage media to highlight both the needs and capacities of older people and to increase their visibility.
- Collaborate with funding bodies to integrate active ageing as a criterion in funding proposals targeting older people.
END
Disability Access Certificates – A Time to Worry ? (I)
Some of you are already hitting the Internet Search Engines … with fierce intent altogether … about Disability Access Certificates (DAC’s) ! Is it time to panic ? No.
For a simple and direct hit, the 2 most relevant Irish Legal Instruments are:
1. Statutory Instrument No. 352 of 2009 – Building Control Act 2007 (Commencement) Order 2009.
This states …
” The 30 September 2009 is appointed as the day on which the provisions of Sections 5 and 6 of the Building Control Act 2007 shall come into operation.”
Section 5 covers the Amendment of Section 6 (Building Control Regulations) of the Building Control Act 1990.
Section 6 covers the Amendment of Section 7 (Appeals) of the Building Control Act 1990.
2. Statutory Instrument No. 351 of 2009 – Building Control (Amendment) Regulations 2009.
This states …
” These Regulations shall come into effect on 1 October 2009, except for the provisions of Article 8 which shall come into effect on 1 January 2009.”
Article 8 covers Disability Access Certificates and Revised Disability Access Certificates.
For you, yourself, to properly examine all of the ‘ins and outs’ of this New Certification Scheme … download the PDF File below … and then search the document (making sure that it is not case-sensitive !) using the phrase ‘Disability Access Certificate’. You will find 99 instances where the phrase is used.
Enjoy !
Click above to view and/or download PDF File
In order to make full sense of all that is happening, and is intended to happen in the not too distant future … there are a few other Legal Instruments, related to the two listed, which also need to be consulted … but that is an exercise meant for masochists !
In comparison, the European Union Lisbon Treaty was a sweet bedtime story ! Seriously !!
Is it time to worry ? Yes.
Here are just a few random ideas for your cogitation …
- If the Department of the Environment, Heritage & Local Government (DEHLG) pays little heed to Submissions made during and after this summer’s ‘consultation’ process … the proposed New Technical Guidance Document M: ‘Access & Use’ will end up looking like a real dog’s dinner of an absolute mess ! FUBAR.
Years were spent in the preparation of the New TGD M. When it does eventually appear, it will be an accurate reflection of technical capacities within both the Department and the National Disability Authority (NDA).
Deeply regretted is the absence of Mr. Kevin Spencer … a gentle soul … from the DEHLG. Things have not been the same since his departure. He knew what he was talking about.
- Who will deal, at a technical level, with Applications for Disability Access Certificates in the Local Authorities ? Will they be competent to do so ? Will their interpretation of the Part M Legal Requirements be harmonized … not just with other/different Authorities … but even with other technical personnel in the same Authority ???
- In order to make this new certification scheme work, will the Guidance Text in Technical Guidance Document M (whatever version appears !) be operated as if it were Prescriptive Regulation … which will be totally illegal ?
This has been exactly the story … for many years … with the Guidance Text in Technical Guidance Document B … in the course of operation of the Fire Safety Certification Scheme. FUBAR.
- If, as I hinted above, the proposed New Technical Guidance Document M: ‘Access & Use’ will be a real dog’s dinner of a mess … falling far short of what can now be reasonably described as minimal accessibility performance (see the Draft International Accessibility-for-All Standard ISO 21542) … this will certainly open Building Owners/Managers of newly completed buildings to Complaints under Irish Equality Legislation. Why is the Disability Sector so inactive with regard to making complaints ?
and finally …
- Are the relevant Irish Decision Makers, as I suggested might happen in a previous post, in the process of actually sleepwalking into an unquestioned acceptance of the inadequate British Standards BS 9999 : 2008 and BS 8300 : 2009 ??? Do they know how to do anything else ?
For some sublime moments of meditation, however, please chew on the information provided at these Pages on the SDI Support WebSite …
Disability Rights & Removing Physical Restrictions on Participation in Society ;
Towards a Sustainable Social Environment, Accessibility-for-All & Facilitation Design (2001 WHO ICF) ;
Fire Evacuation-for-All & Principles of Fire Engineering.
END
BER Certificates – A Proposal for What’s Next ? (VI)
The other day, I received an impassioned e-mail … an extract …
” We are an energy rating company involved in a campaign for enforcement. Yesterday, we made a presentation to SEI (see attached). It was the result of a 2-month attempt to meet with the DEHLG and SEI. You are right in your article about them ‘not WANTING to know’.
My only question is: do you have any ideas on what’s next ? ”
The BER Gold Rush Soap Opera so far …
There are thousands of BER Assessors out there around the country … each having paid a ‘pretty penny’ for training, for exams, and for registration … and work on the ground is very scarce. A significant number of those Assessors have an inadequate understanding of building construction … while some of the people who are involved in providing Validated BER Training Courses are, to put it mildly, similarly unendowed.
Energy Ireland (SEI) is the Issuing Authority, but it has absolutely no experience as a Control Authority. And has anyone bothered to read the relevant Legal Disclaimer on the SEI WebSite ? It does, however, have a large marketing budget … those smarmy, wall-to-wall radio advertisements, which refer to the ‘property game’, continue to irritate my sensitive ear drums !
Apparently … 20% of BER Assessments are turning out to be faulty, i.e. they have not been properly carried out by Registered BER Assessors. In other words, 1 out of every 5 BER Certificates needs to be thrown in the paper recycling bin. Furthermore … I have discussed in one of my first posts how there is only a very tenuous relationship between a BER Certificate and the ‘real’ energy performance of a specific building. And in relation to ‘real’ buildings … there is a general non-compliance rate of 70% on Irish Building Sites with the minimal energy performance requirements in Part L of the Irish Building Regulations.
SEI’s Register of BER Assessors is unreliable.
What a magnificent waste of time, energy and money !
Some Comments on a Recent BER Certificate
Sitting on the desk to the left of my computer keyboard is a recent Building Energy Rating (BER) Certificate and its accompanying Advisory Report … issued sometime during the second half of May 2009 … for a private, single-occupation dwelling house somewhere in Leinster … and using the DEAP Version 3.0.0 computer software. I do not wish to identify the specific Certificate.
This particular BER Certificate Documentation comprises:
- the actual BER Certificate ;
Can I be sure that the correct choices were made with regard to the software input information/data ? No.
- its accompanying BER Advisory Report.
Not missing any marketing trick, and in stark contrast to the actual BER Certificate … there is an Energy Ireland (SEI) Logo at the top of the first page of the Advisory Report … and an elaborate footer with SEI contact information on the last page.
Meanwhile, there is not one single mention of Statutory Instrument No. 666 of 2006: European Communities (Energy Performance of Buildings) Regulations 2006 anywhere in the Report … nothing to explain that SEI is the Issuing Authority for the purposes of this national legislation … or that there is such a thing as a BER Register … etc, etc, etc.
The Advisory Information provided in the Report is too vague to be useable … and there are silly typographical errors.
Did the BER Assessor request any information from the owner about the house ? It is impossible to tell whether he/she made any such request.
Am I assured that the BER Assessor had an adequate understanding of building construction ? Definitely not.
[ Specific comments about other issues might identify the actual BER Certificate. ]
What’s Next ?
The following remarks are directed at those BER Assessors, building owners, landlords, building professionals and general punters who do wish to spend their money on something worthwhile … something which has meaning, and is useful.
Energy Labelling of Buildings, just as in the case of other energy using/consuming industrial products … is positive and very worthwhile.
The legal basis established by European Union (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 good start.
I would much prefer if this Directive were linked in more directly to the Extensive Framework of the Construction Product Directive … EU Council Directive 89/106/EEC, of 21 December 1988, on the Approximation of Laws, Regulations and Administrative Provisions of the Member States relating to Construction Products. The reason that this has not already happened is because of a startling lack of horizontal integration between the different Directorates-General in the European Commission.
If there are problems with how the BER Legislation is operating at national level in Ireland, it is not the fault of Brussels or Directive 2002/91/EC … it is our problem … and it is up to us to remedy the situation.
There are 3 Immediate Priorities for Building Energy Rating in Ireland:
- increase accuracy ;
- reduce uncertainty ;
- improve reliability.
An Initial Proposal …
Without amending any legislation … and without reference to the Department of the Environment, Heritage & Local Government (DEHLG), Energy Ireland (SEI) and the Construction Industry Federation (CIF) … none of which have shown any proper leadership in relation to these issues, but seem interested only in playing games …
1. The BER Certificate
Attach a Single-Page Appendix to the actual BER Certificate which clearly shows the Input Information/Data selected by the Registered BER Assessor. Include a Statement of Measurement/Calculation Uncertainty concerning the Energy Rating Process … and a Statement of Competence in Building Construction, with the Assessor’s Signature … at the bottom of the page.
Show the Page Number on the Certificate as Page No.1 of 2 … and on the Appendix as Page No.2 of 2.
A BER Certificate should not be valid without this Appendix.
2. The Accompanying BER Advisory Report
Generally … tighten up the information provided in the Report, make it easier to understand … and make it more useable ! DO NOT TIE energy performance, or any other aspects of building performance, to the minimal – ‘abysmal’ – performance targets described in the guidance texts of Technical Guidance Documents A-M in the Irish Building Regulations. We have to aim much, much higher !! The European Union’s 2020 Climate Change Targets will be heavy going for Ireland, even if there is no agreement in Copenhagen at the end of 2009. And … insert Page Numbers !!!
Include Additional Components in the BER Advisory Report:
- Findings of a Formal Interview/Questionnaire Survey with the building owner, landlord or manager – some questions should have an open format ;
- Results of Infra-Red Thermography and Air Seepage Testing – discussed at length in previous posts ;
- Results of a Radon Test – as already discussed, an important indicator of Indoor Air Quality and whether or not there is adequate Ventilation in the building.
Institutions of National Governance – Criminally Dysfunctional ?
2009-05-28: 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.
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END
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.]
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