Energy Performance of Buildings
Fixing ‘Priory Hall’ in Dublin – Practical Solutions Needed Now !
2011-10-18: A large ‘can of worms’ has recently been opened in Ireland …
For the last few days, including today, I have been listening intently to Joe Duffy on the RTE Radio ‘Liveline’ Programme at lunchtime. Joe is being very cautious because he cannot quite believe his ears … either about the unfolding harrowing events for occupants in ‘Priory Hall’, Donaghmede, Dublin 13 – a Private, Multi-Storey Apartment Development – or the tales and anecdotes about Irish Building Sites during the Celtic Tiger Years.
This will be of no consolation to anybody … but the big surprise, for me, is that there is so much public shock. ‘Priory Hall’ is the Tip of the Iceberg ! Ireland’s current dysfunctional approach to the development of Our(!) Built Environment … has been designed (for want of a better word) in a chaotic, haphazard and malevolent way … to end up in exactly the sort of mess which we are all now witnessing in North County Dublin.
Just to be clear … what has been happening in the Irish Construction Industry, during the boom years, has been happening for twenty years all over the country … more precisely, since the introduction of Legal National Building Regulations, with NO Effective Building Control, in 1991 … and, before that again, in those parts of this jurisdiction, outside of the major urban areas having Legal Building Bye-Laws, and Effective Building Control, i.e. mandatory inspections by competent local authority personnel at the foundation level and drainage level of all building sites … and, depending on the type of project, occasional or frequent inspections above ground level.
[ 1991: Statutory Instrument No.304 of 1991 - Building Control Act, 1990 (Commencement Order), 1991; Statutory Instrument No.305 of 1991 - Building Control Regulations, 1991; Statutory Instrument No.306 of 1991 - Building Regulations, 1991 ]
And the biggest joke of all … is that the sum of the many resources, both human and material, required to repair sub-standard construction throughout Ireland … will count as a positive contribution towards the economic indicator of GDP (Gross Domestic Product) ! FUBAR
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Colour photograph showing 'Priory Hall' ... a private, multi-storey apartment development located in North County Dublin, Ireland. Click to enlarge.
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PRACTICAL SOLUTIONS NEEDED NOW
What I have not been hearing from the radio, or reading in the newspapers, is practical solutions.
Lest there be any doubt … this is one of the professional services we provide at Sustainable Design International !
So … how do we fix Priory Hall as the situation now presents itself … in such a way that, as soon as it is practicable, a satisfactory level of long-term safety, protection, convenience and comfort will be provided for the occupants of Priory Hall … and the social wellbeing of the local community, there, can be restored.
Afterwards … we can worry about who’s responsible, and about the reasons for the many ‘system’ failures in Ireland.
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FIXING ‘PRIORY HALL’ IN DUBLIN
The following list of practical suggestions … a simple roadmap … is addressed to the Owners and Occupants of Apartments in Priory Hall.
As they have a large vested interest in the problems of Priory Hall … either directly or indirectly … no assurances or undertakings should be accepted, on face value, from either Dublin City Council (DCC) or the Department of the Environment, Community & Local Government (DECLG) … or their representatives.
1. Informed Consent of Apartment Owners and Occupants
Demand that the Informed Consent of the Owner/Occupant of an Apartment is required, in writing, before any necessary Corrective/Repair/Refurbishment Works are carried out …
Informed Consent: Consent freely obtained – without threats or improper inducements – after appropriate disclosure to a person of relevant, adequate and easily assimilated information in a form and language understood by that person.
2. ‘As Constructed’ Drawings & Specification of Entire Development
If they exist … we’re on the way ! But, if they don’t exist … and they may not … demand that an ‘As Constructed’ Survey of the Entire Development be carried out immediately.
Demand to see a copy of the Detailed ‘As Constructed’ Drawings, and Specification, for the Entire Development.
CHECK the adequacy of the Detailed Drawings and Specification !
At this stage, remember … all of the emphasis must now be placed on actual construction … not on paperwork ! The ‘As Constructed’ Survey Drawings and Specification are only a means towards a satisfactory end … that’s all !!
3. Failures to Properly Comply with Current Building Regulation Requirements A to M (Second Schedule to Irish Building Regulations)
Demand to see a Detailed Schedule of the many failures to properly comply with current Building Regulation Requirements, i.e. Parts A to M in the Second Schedule to the Building Regulations, as amended.
Do not entertain, even for a moment, any discussion about past legal building regulation requirements, which were in force at the time of initial design or construction !
An important point to note ! The Guidance Texts in, for example, Technical Guidance Document B: ‘Fire Safety’ are merely that … GUIDANCE ! This guidance is not infallible … and in a few respects, is entirely inadequate … for example, when dealing with the structural performance of buildings during conditions of fire, and the ‘cooling phase’ immediately afterwards … and the fire evacuation of people with activity limitations, in which case the guidance actually ensures that fire evacuation is made extremely difficult, if not prevented altogether !
Do not be sucked in to any conversations about what is stated, or not stated, in the Technical Guidance Documents. This is irrelevant. The Law mandates proper compliance with the Requirements !
Some people may even attempt to quote from the Building Regulation Approved Documents for England & Wales. Just tell them to take a long jump off a short pier … suggest Howth Harbour !
Become very, very suspicious whenever there is a use of, or reference to, the term ‘Substantial Compliance’ !!
CHECK the adequacy of this Detailed Schedule ! And … ensure that it is Comprehensive !!
4. The Necessary Corrective/Repair/Refurbishment Works
Demand to see Full Detailed Information, in the form of annotated drawings and descriptive texts, etc., etc … on the exact nature, timetable and phasing of all of the Corrective/Repair/Refurbishment Works which are necessary to effectively solve the serious problems in the Development.
Beware of decorative solutions, which look good to a superficial visual inspection in ambient conditions … but don’t actually solve anything !
CHECK the adequacy of this Full Detailed Information !
5. Independent Technical Control of Construction Works
Demand only Category A Construction Execution of the necessary Corrective/Repair/Refurbishment Works …
Category A Construction Execution:
(a) Supervision of the works is exercised by appropriately qualified and experienced personnel from the principal construction organization ;
(b) Regular inspections, by appropriately qualified and experienced personnel familiar with the design and independent of the construction organization(s) … and other vested interests … are carried out to verify that the works are being executed in accordance with the design.
Demand receipt of a clear undertaking, in writing, that this will be the case … before any Corrective/Repair/Refurbishment Works commence.
And remember these words from the 2005 Final Report of the U.S. National Institute of Standards & Technology (NIST) on the 9-11 World Trade Center Tower Collapses …
” NIST urges state and local agencies to rigorously enforce building codes and standards since such enforcement is critical to ensure the expected level of safety. Unless they are complied with, the best codes and standards cannot protect occupants, emergency responders, or buildings.”
CHECK the adequacy of the Proposed Method of Independent Technical Control during execution of the Corrective/Repair/Refurbishment Works !
6. Meeting & Discussion with Other Owners/Occupants
Do not act alone … meet the other Owners/Occupants, and discuss issues with them. Share and collate all available information together. Try to identify information gaps. If you do not understand something … ask !
When, and only when, you are happy … signal your Informed Consent that works should commence.
7. Commencement of Corrective/Repair/Refurbishment Works
Visit the Construction Site Office regularly … to show that you are taking a keen interest in what is happening. Keep your eyes and ears wide open.
Expect that you will not be permitted to just wander around the Site. Construction Sites are one of the most hazardous ‘workplaces’ in this country !
CHECK the adequacy of the Independent Technical Control actually being undertaken.
Demand to be updated, regularly, and at the very least on the progress of Corrective/Repair/Refurbishment Works at your Apartment … in the Common Areas of your Block … and throughout the full extent of the Approach Routes to your Block Entrances and Exits.
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Advisory Note: Should you, or the Residents’ Committee of your Building or Development, be concerned about any matter discussed in this Post … please contact C.J. Walsh by e-mail: cjwalsh@sustainable-design.ie or by phone: (01) 8386078 / +353 1 8386078.
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END (for now, but to be continued soon !)
BER Certificates & New Improvements to French DPE System
2011-09-15: Further to my post, dated 8 June 2009 …
On 13 September 2011 … the French Ministère de l’Écologie, du Développement Durable, des Transports et du Logement announced 6 measures to improve their National DPE (Diagnostic de Performance Energétique) System … equivalent to our BER (Building Energy Rating) System in Ireland.
In the context of my earlier post, you will find these improvements interesting …
Colour image showing the recently announced revision to the National DPE (Diagnostic de Performance Energétique) Building Rating System in France. The new system will enter into force on 1 January 2012.
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Nathalie Kosciusko-Morizet et Benoist Apparu, Secrétaire d’Etat chargé du Logement, ont présenté, Mardi 13 Septembre 2011, 6 Mesures pour Améliorer et Fiabiliser le Diagnostic de Performance Energétique (DPE). Pour plus de transparence, une amélioration des méthodes de calcul, une meilleure formation des diagnostiqueurs et un contrôle plus efficace de la profession.
Rendu obligatoire depuis le 1er Janvier 2011 par le Grenelle Environnement, le Diagnostic de Performance Energétique (DPE) est amené à jouer un rôle de plus en plus important dans les décisions d’acquisition ou de location de logements.
Un Outil Apprécié des Français
La Performance Energétique des Bâtiments représente un double enjeu: elle permet d’améliorer le pouvoir d’achat des Français par une meilleure maitrise des dépenses d’énergie, et par ailleurs, elle participe à la lutte contre le changement climatique.
[ Aujourd’hui, le secteur du bâtiment représente 42.5 % des dépenses d’énergie. Il est le plus gros consommateur d’énergie en France parmi l’ensemble des secteurs économiques. ]
Désormais connu du grand public, le dispositif bénéficie d’une image positive auprès des Français puisqu’en Mars 2011, 80% des ménages considèrent la consommation énergétique du logement comme un critère de choix très important, et 60% déclarent que s’ils étaient appelés à mettre leur appartement en vente, ils envisageraient de faire des travaux pour en améliorer la performance énergétique.
« Le DPE a été très rapidement adopté par les Français et est devenu un critère essentiel pour guider leur choix d’acquisition et location de logement. Il était donc important d’en faire un outil dans lequel ils ont une entière confiance. Les mesures qui vont être mises en place ont pour but de faire de l’étiquette énergétique un outil de référence incontestable, permettant aux Français d’améliorer leur pouvoir d’achat en évaluant et en maitrisant mieux leur consommation d’énergie » ont souligné les Ministres.
6 Mesures pour une Etiquette Energétique Fiabilisée
Ce programme s’axe autour de 6 mesures portant sur plus de transparence, une amélioration des méthodes de calcul, une meilleure formation des diagnostiqueurs ou encore un contrôle plus efficace de la profession.
1. Une Meilleure Transparence vis-à-vis des Particuliers: Le diagnostiqueur devra à présent expliciter les données qu’il renseigne auprès du particulier à travers un relevé détaillé. Cela permettra au particulier d’être entièrement informé sur la façon dont a été réalisé son document. La remise d’un document officiel limitera également le risque de DPE ‘frauduleux’.
2. Amélioration de la Méthode de Calcul: Pour un résultat plus fiable, il s’agit d’augmenter le nombre de données à analyser afin de faire un calcul plus précis de la performance énergétique.
3. Utilisation de Logiciels Validés par le Ministère: Pour un meilleur encadrement des logiciels utilisés, il s’agit de limiter la liste de logiciels autorisés à générer des DPE aux logiciels ayant été soumis à une procédure d’évaluation menée entre 2008 et 2010 par le ministère et l’Agence de l’Environnement et de la Maîtrise de l’Energie (ADEME).
4. Une Base de Données des DPE sera Mise en Ligne: Les statistiques permettront, entre autre, de nourrir l’élaboration des stratégies nationales et locales.
5. Une Montée en Compétence des Diagnostiqueurs, en augmentant le niveau de difficulté des examens. Jusqu’à aujourd’hui, un seul examen existait, à présent 2 niveaux de difficulté seront mis en place selon la mention (mention « bâtiments d’habitation » ou « tous types de bâtiments » – tertiaires, publics, privés, etc.).
6. Un Contrôle plus Efficace, avec pour les particuliers, un annuaire des diagnostiqueurs mis en ligne par le ministère, et la mise en place d’une enquête de la Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes (DGCCRF) dans le secteur du diagnostic immobilier dans le cadre de sa mission de protection économique du consommateur …
L’ensemble de ces mesures, qui entreront en vigueur dès le 1er Janvier 2012, permettront l’amélioration d’un outil encore récent, mais dont l’utilité et l’efficacité sont déjà démontrées.
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END
New EU Construction Product Regulation 305/2011 – Halleluiah !
2011-09-13: Closely related to our current discussions about the 10th Anniversary of the 9-11 WTC Incident in New York …
For more years than I care to remember … I have been involved, directly and/or indirectly, with piecing together the edifice that is European Union (EU) Council Directive 89/106/EEC Interpretation … a lumbering giant which has failed, miserably, to bring about the necessary conditions for the efficient operation of an effective European Economic Area (EEA) Single Market for Construction Products.
Proper Implementation has always been the fatal weakness of this ‘system’ … because on the ground, in Europe, no such Single Market exists in reality. Politicians, at both European and national levels and typically lacking a competence on technical issues, believe otherwise. Bureaucrats, at both European and national levels and always lacking a working familiarity with the full scope of EU Treaties, do not want to recognise this fundamental truth.
To refresh your memories … the full title of the now Repealed EU Directive 89/106/EEC was …
Council Directive, of 21 December 1988, on the Approximation of Laws, Regulations and Administrative Provisions of the Member States relating to Construction Products
ANNEX I of that Directive described 6 ‘Essential Requirements’ …
- Mechanical Resistance & Stability
- Safety in Case of Fire
- Hygiene, Health & the Environment
- Safety in Use
- Protection against Noise
- Energy Economy & Heat Retention
The unusual feature of this particular New Approach Directive was that the ‘suitable’ construction products, i.e. products which could be shown to be fit for their intended use, had to facilitate the construction works in satisfying all of the 6 Essential Requirements, taken together as a whole … not just some of the Requirements.
Down through the years, however, it has been deeply frustrating … to have to pressure the TÜV Organization in Germany, for example, to issue proper Test Reports to their German Clients … or, as recently as last July, to have to explain basic information about CE Marking to Manufacturers. And there appears to be no proper infrastructure in any EU Member State to check and control CE Marks on industrial products generally, never mind construction products.
Further up the chain, there were also problems. In developing a family of 6 Separate Interpretative Documents for each of the Essential Requirements … important cross linking concepts between Requirements, e.g. Fire-Induced Progressive Building Collapse, fell into a deep void, almost never to be heard from again. And concepts explicitly referenced in ANNEX I, such as the Safety of Rescue Teams (i.e. firefighters), received little or no attention in those Interpretative Documents … which then had a serious knock-on effect when Harmonized European Standards, European Technical Approvals (ETA’s) and EuroCodes were being drafted, based on the guidelines in Interpretative Documents.
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Lucca, Italy - Early Morning on 21 August 2011. Photograph by CJ Walsh. Click to enlarge.
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Halleluiah ! At Long Last … published on 4th April 2011, in the Official Journal of the European Union … the new EU Construction Product Regulation 305/2011 … the full title of which is …
Regulation (EU) No. 305/2011 of the European Parliament and of the Council, of 9 March 2011, laying down Harmonized Conditions for the Marketing of Construction Products and Repealing Council Directive 89/106/EEC
ANNEX I of these New Regulations now describe 7 ‘Basic Requirements for Construction Works’ … requirements which are appropriate to the needs of our time. Please note the newly revised/additional texts, highlighted in red …
Construction works as a whole and in their separate parts must be fit for their intended use, taking into account in particular the health and safety of persons involved throughout the life cycle of the works. Subject to normal maintenance, construction works must satisfy these basic requirements for construction works for an economically reasonable working life.
1. Mechanical Resistance and Stability
The construction works must be designed and built in such a way that the loadings that are liable to act on them during their construction and use will not lead to any of the following:
(a) collapse of the whole or part of the works ;
(b) major deformations to an inadmissible degree ;
(c) damage to other parts of the construction works or to fittings or installed equipment as a result of major deformation of the load-bearing construction ;
(d) damage by an event to an extent disproportionate to the original cause.
2. Safety in Case of Fire
The construction works must be designed and built in such a way that in the event of an outbreak of fire:
(a) the load-bearing capacity of the construction works can be assumed for a specific period of time ;
(b) the generation and spread of fire and smoke within the construction works are limited ;
(c) the spread of fire to neighbouring construction works is limited ;
(d) occupants can leave the construction works or be rescued by other means ;
(e) the safety of rescue teams is taken into consideration.
3. Hygiene, Health and the Environment
The construction works must be designed and built in such a way that they will, throughout their life cycle, not be a threat to the hygiene or health and safety of workers, occupants or neighbours, nor have an exceedingly high impact, over their entire life cycle, on the environmental quality or on the climate during their construction, use and demolition, in particular as a result of any of the following:
(a) the giving-off of toxic gas ;
(b) the emission of dangerous substances, volatile organic compounds (VOC’s), greenhouse gases or dangerous particles into indoor or outdoor air ;
(c) the emission of dangerous radiation ;
(d) the release of dangerous substances into ground water, marine waters, surface waters or soil ;
(e) the release of dangerous substances into drinking water, or substances which have an otherwise negative impact on drinking water ;
(f) faulty discharge of waste water, emission of flue gases or faulty disposal of solid or liquid waste ;
(g) dampness in parts of the construction works or on surfaces within the construction works.
4. Safety and Accessibility in Use
The construction works must be designed and built in such a way that they do not present unacceptable risks of accidents or damage in service or in operation such as slipping, falling, collision, burns, electrocution, injury from explosion and burglaries. In particular, construction works must be designed and built taking into consideration accessibility and use for disabled persons.
5. Protection against Noise
The construction works must be designed and built in such a way that noise perceived by the occupants or people nearby is kept to a level that will not threaten their health and will allow them to sleep, rest and work in satisfactory conditions.
6. Energy Economy and Heat Retention
The construction works and their heating, cooling, lighting and ventilation installations must be designed and built in such a way that the amount of energy they require in use shall be low, when account is taken of the occupants and of the climatic conditions of the location. Construction works must also be energy-efficient, using as little energy as possible during their construction and dismantling.
7. Sustainable Use of Natural Resources
The construction works must be designed, built and demolished in such a way that the use of natural resources is sustainable and in particular ensure the following:
(a) re-use or recyclability of the construction works, their materials and parts after demolition ;
(b) durability of the construction works ;
(c) use of environmentally compatible raw and secondary materials in the construction works.
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I will be anxious to see if the full intent of these ‘Basic Requirements for Construction Works’ is properly transposed into the new interpretative framework (comprising Delegated Acts, Harmonized Standards, etc., etc.) of EU Regulation 305/2011 …
and …
I will be even more anxious to see how and when specific output (Harmonized Standards, European Technical Approvals (ETA’s) and EuroCodes) from the obsolete interpretative framework of the Repealed Directive 89/106/EEC is revised and updated !
and, finally …
When will we ever see the vital Infrastructure of Implementation operating successfully in the EU Member States … so that Manufacturers can reap the enormous benefits of an effective EEA Single Market for Construction Products ??
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END
Ireland’s Proposed Climate Change Legislation – Shambolic !!
2011-01-30: ANYWAY … continuing on from yesterday …
In December (2010) … Mr. John Gormley T.D., Irish Minister for the Environment, Heritage & Local Government published the 2010 Climate Change Response Bill. This proposed legislation is intended to set out a range of measures to statutorily underpin Ireland’s transition to a sustainable, climate change resilient and low carbon-based fuel consuming society … not forgetting, always (!), that there are other Greenhouse Gases (GHG’s) specified in the UNFCCC’s 1997 Kyoto Protocol besides Carbon Dioxide (CO2) … which most people do forget.
The Minister had then invited interested parties to submit their views on the Bill – available to download from the Department of the Environment, Heritage & Local Government (DEHLG) WebSite at http://www.environ.ie/ … by Friday, 28 January 2011. Three other documents which were relevant to this ‘consultation’ are: an Explanatory and Financial Memorandum on the proposed legislation, the Bill’s Regulatory Impact Assessment and the Minister’s 2011 Carbon Budget Dáil Statement.
In his 2011 Carbon Budget Speech to the Dáil (Irish Parliament), the Minister had proclaimed the following …
” In providing a legislative underpinning for proactive transition, it (the 2010 Bill) presents the Irish people as an informed and progressive society pursuing a smart economy in the truest sense of the term – an economy that is highly productive, competitive, resource-efficient and environmentally sustainable.” and
” The Bill is both innovative and inspirational, and I look forward to a frank and honest public debate when it is published.”
WOW !!! Hold De Horses !!!!
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Two important national lobby groups have recently thrown some spanners into the works … the Irish Farmers’ Association (IFA) raised some positive and interesting issues which should be brought to the attention of DG CLIMA in the European Commission … see this Page on the IFA WebSite … http://www.ifa.ie/CrossSectors/ClimateChangeandRenewables.aspx … while the Irish Business & Employers Confederation (IBEC) have been predictably negative and a right pain in the ass … see this Page on their WebSite … http://www.ibec.ie/IBEC/Press/PressPublicationsDocLib3.nsf/vPages/2BEBCAA836D7D6E08025781D00428C39?OpenDocument
The well-publicized positions adopted by these lobby groups prove the point, however, that far more than slick marketing campaigns are required to raise popular awareness about climate change … to properly mobilize society for climate change action, i.e. adaptation as well as mitigation … and reliable implementation.
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MEANWHILE …
As far as Irish Senior Civil Servants are concerned … the temporary, blow-in politicians (also referred to, by them, as ‘defecating birds of passage’) … in this particular case, Mr. John Gormley … have merely departed the scene … this time, a little earlier than expected. But, the permanent system of national dysfunctional governance, i.e. the Civil Service, continues to ride on into the golden sunset … serving their own interests, and not always the country’s !
Whatever is happening at a political level … you should still have regarded Friday, 28 January 2011 … as the latest date for receipt of written responses on Ireland’s Proposed Climate Change Response Bill. If slightly late, get those responses in anyway … as early as possible after the weekend !
The Civil Servants in the Department of the Environment, Heritage & Local Government (DEHLG) need all the help that they can get !!
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IRELAND’S NEARLY-ACTUAL CLIMATE CHANGE PERFORMANCE
On 14 December 2010, the Economic & Social Research Institute (ESRI) published a report: ‘The Energy & Environment Review 2010′ … available for download at http://www.esri.ie/ … which contained a certain Figure 6. Please bear in mind that there are large uncertainties associated with all of the data contained in the document (see more below) … a point acknowledged by the ESRI …
Colour image showing Figure 6: 'Greenhouse Gas Emissions by Gas According to the Low Growth Scenario' ... from the Economic and Social Research Institute (ESRI) Report: 'The Energy & Environment Review 2010', published in December. Click to enlarge.
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Ireland’s Climate Change Action to date, i.e. effective Climate Change Mitigation and Adaptation Implementation, has been laboriously slow and lethargic. It may best be characterized as ‘Business as Usual’, combined with some ‘Cosmetic Tinkering at the Edges’ as the need arises … the universal excuse, almost a mantra, being that “the competitiveness of the national economy must not be impaired”. National Performance has been guided by an official policy of exploiting to the maximum all of the UNFCCC Kyoto Protocol’s Flexibility Mechanisms while, at the same time, showing a stark indifference to Climate Change Adaptation … an over-reliance on Marketing Campaigns in the public media as opposed to mandatory implementation on the ground … and a preference for ‘Soft’ Performance Estimation on paper/computer monitor screen rather than the more painful ‘real’ performance calculation, which would generate reliable data and statistics to be managed by Ireland’s Central Statistics Office (CSO), in co-ordination with EuroStat in Luxembourg.
Figure 6 from the 2010 ESRI Report … indicates that Official Ireland only ever had a short-term strategy, which was to meet the Kyoto Protocol’s 2012 GHG Emission Reductions Target … on paper ! Right now, it looks like we may only just manage to meet that Target because of the current serious economic recession. This performance improvement … temporary only … masks fundamental problems within Irish Society. After 2012, all bets are off … as we won’t be in a position to meet any reasonably foreseeable EU or International GHG Emission Reduction Targets. If economic growth takes off again, in Ireland, during the second half of this decade … not a completely mad notion … we will be in real trouble !
The Department of Environment, Heritage & Local Government (DEHLG) lacks strong and competent political direction and the institutional capacity to effectively co-ordinate, oversee and implement National Climate Change Action. For this reason, closer scrutiny of the Department’s activities, from the Dáil Committee System, will be an absolute necessity.
Ireland’s proposed climate change enabling legislation … the 2010 Climate Change Response Bill … is the belated manifestation of a shambolic and pathetically inept effort on the part of Mr. John Gormley, T.D. … and the Senior Civil Servants in the Department of the Environment, Heritage & Local Government (DEHLG) !
Why, So, Because … ?
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SOME SPECIFIC COMMENTS ON THE 2010 CLIMATE CHANGE RESPONSE BILL
1. In the light of elaborate claims made about this proposed legislation and also, for example, the separate project to establish an International ‘Green IFSC’ in Dublin … the 2010 Climate Change Response Bill will be closely examined outside Ireland … particularly by the most advanced ‘developing’ economies and the ‘least developed’ economies of the world.
However, a keen awareness about the highly divisive and difficult political issues at the heart of current international climate change negotiations would have dictated that the following be discussed in a Preamble or Introductory Section to the Bill:
- An acknowledgement of Ireland’s Historical Responsibility for contributing to global climate change ;
- A national commitment to fully support the move towards an Internationally Agreed Cap of 1.5 degrees Celsius on the planetary temperature rise ;
- A national commitment that Ireland will meet its International & European Union Climate Change Obligations through the efforts of Irish Society alone. In other words, we will not seek to benefit, unfairly, from any of our Foreign Development Aid to countries in Africa and Asia … or to projects in Africa, Asia, the Western Balkans, Eastern Europe, Palestine or the Caribbean.
[All such Foreign Development Aid from Ireland should be immediately 'climate change' proofed.]
2. It is only economists who mistakenly believe that everything in society is merely an ‘input’ to economic ‘output’. Mercifully, the rest of us know otherwise. A Society is much, much more than its Economy !
It is a fundamental value and principle that All Aspects of Sustainable Human & Social Development must be taken into account at the same time and with the same weight. A blinkered approach which only considers the environmental aspects of this overarching concept is damaging, and seriously counter-productive in the longer-term.
The case study of the Proposed Shannon River – Dublin City Region Water Supply Project … discussed in a previous post … very clearly shows that there is a symbiotic Relationship between the Concept of Sustainable Human & Social Development and the Reality of Climate Change … a robust link which is critical to the development of an elusive Global Consensual Response to the threat … and essential for the effective implementation of any Climate Change Strategy in Ireland.
The Existing Lines 11-15 in the 2010 Bill are conceptually flawed … and drafted carelessly and imprecisely. Revise these lines accordingly …
TO MAKE PROVISION FOR THE SETTING, AND ACHIEVEMENT, OF NATIONAL GREENHOUSE GAS EMISSION REDUCTION TARGETS TO FURTHER TRANSITION TO A SUSTAINABLE, CLIMATE CHANGE RESILIENT AND LOW CARBON-BASED FUEL CONSUMING SOCIETY ;
For Consistency … Revise Section 5 (3) (a) – Section 5 (6) (a) – Section 6 (1) (a) – Section 9 (1) – the final portion of Section 10 (2) – and Section 11 (1) (c) of the Bill.
3. No satisfactory explanation has ever been given, in Ireland, for not choosing a Common Baseline Year of 1990 for all of the Kyoto Greenhouse Gases. Revise Section 2 (2) of the Bill as follows …
For the purposes of this Act -
(a) the baseline year applicable to a class A greenhouse gas shall be 1990; and
(b) the baseline year applicable to a class B greenhouse gas shall be 1990.
In Section 4 (1) – Section 4 (2) – and Section 4 (3) of the Bill … Revise all GHG Emission Reduction Targets and express them, clearly and simply, in terms of the single Common Baseline Year of 1990.
Thankfully … Ireland’s GHG Emission Reduction Targets will be dictated to us as a result of Agreements at International and/or European Union levels. Any aspirations with regard to Ireland taking a lead role in climate change action, at any level, are pure fantasy !
4. National GHG Emissions – Towards Reliable Data and Statistics
At present … the National ‘GHG Emission’ Database is managed by the Environmental Protection Agency (EPA). The EPA is not a statistical organization, and necessary statements of uncertainty are not presented with emissions data. The National ‘GHG Emission’ Database is unreliable.
A major part of the EPA’s National ‘GHG Emission’ Database is dependent upon National Energy Consumption and Efficiency Performance Data. The National ‘Energy’ Database is managed by Energy Ireland (SEAI). Energy Ireland is also not a statistical organization, and necessary statements of uncertainty are not presented with energy data. The National ‘Energy’ Database is unreliable.
For a number of years, however, Energy Ireland has been in possession of reliable information which shows that there is a dramatic difference between the claimed ‘theoretical’ energy conservation and efficiency performance of buildings at design stage … and the actual energy performance of ‘real’ buildings … such is the poor quality of construction on Irish Building Sites. It is therefore possible to state, with confidence, that the National ‘Energy’ Database managed by SEAI is corrupt !
[See previous posts ... Energy Ireland has consistently refused to release the full details of this information into the public domain. I know, because I am tired asking !]
To be reliable … National ‘GHG Emission’ and ‘Energy’ Databases must be managed directly by the Irish Central Statistics Office (CSO), in co-ordination with EuroStat in Luxembourg … and necessary statements of uncertainty must always be presented with data.
A revised Climate Change Response Bill must confront this serious issue now … and deal with it properly.
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Climate Change ?#$#? … 2007 SDI Letter to John Gormley !
2011-01-29: Some people say that a week is a long time in politics … but, here in Ireland, during the last two weeks … every single day feels like a year ! To the uninformed outside observer, this may have all the appearance of being an elaborate circus … but, we like our politics to be complex, interesting and very frothy.
Briefly … the Irish Green Party has recently removed itself, awkwardly, from the Ruling Coalition Government in this country … and the Green Party Agenda has gone up in smoke … definitely a Climate Changing Greenhouse Gas ! Mr. John Gormley T.D., Leader of the Green Party, has therefore resigned as Minister for the Environment, Heritage & Local Government … and his Green Party departmental colleague, Mr. Ciarán Cuffe T.D., Minister of State with special responsibility for Sustainable Transport, Horticulture, Planning and Heritage at the Departments of the Environment, Transport and Agriculture has also resigned.
With all of Ireland’s current economic woes … this decision by the Green Party has ensured that ‘Climate Change’ is fast dropping off the list of national priorities.
However, as a result of these political shenanigans … the word ‘Green’ has received a severe hammering and will induce a nasty taste in the mouths of many Irish Voters during the next few weeks which lead up to a General Election. To be honest, I heartily cheer this development … since ‘GREEN’-ness, i.e. a sole and blinkered consideration for the Environmental Aspects of Sustainability is a ‘pre-version’ (fans of the film: ‘Dr. Strangelove’ will understand what I mean) of Sustainable Human & Social Development. It is also a peculiar quirk of ‘greens’ that they love the environment … but hate people !
As a prelude to what I will say about the proposed enabling legislation for climate change action in Ireland … the 2010 Climate Change Response Bill … I thought that it would be interesting to reveal the contents of a submission I made to Mr. John Gormley back in late 2007. Concerning his reaction … I wondered how it was possible for anybody to write such a long letter in reply, and say nothing.
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Mr. John Gormley T.D., 2007-12-18.
Minister for the Environment, Heritage & Local Government,
Department of the Environment, Heritage & Local Government (DEHLG),
Custom House – Dublin 1.
Re: Your Meeting with IIEA on Friday, 7th December 2007
Dear Minister,
At the Meeting with the Institute of International & European Affairs (IIEA), in North Great George’s Street, I raised two points directly with you:
i) The Great Difference between ‘Real’ Building Energy Performance and Claimed ‘Theoretical’ Performance. In a context where the mandatory use of long wave infra-red thermal imagery will not be introduced in the Revised Technical Guidance Document L of the Building Regulations, due to be issued shortly, and there will continue to be No Effective System of Building Control anywhere in the country … no relationship exists between Claimed ‘Theoretical’ Performance and ‘Real’ Performance, such is the poor quality of construction on Irish Building Sites. The Energy Numbers which continue to be produced by Sustainable Energy Ireland are – almost – pure fantasy.
ii) Sourcing of Climate Change Research & Models for Necessary Institutional Reform Must Extend Beyond Britain. The following is taken from the Irish National Climate Change Strategy 2007-2012 (page 45) …
‘ Ireland has also engaged in an exchange of information on impacts and adaptation activities through the British-Irish Council. This initiative has focused on exchanging data on research projects which have improved the understanding of climate change impacts at a local level.’
I suggested to you that if this were, actually, to be the approach to Research in Ireland … we will be in serious trouble. Furthermore, far too many people in important organizations (including the IIEA) are only looking across the water for Models of Necessary Institutional Reform. We must also, in Ireland, look to the rest of Europe and Japan to find the Best Research and the Most Effective Institutional Models.
Please see the enclosed World Business Council for Sustainable Development (WBCSD) Summary Report: ‘Energy Efficiency in Buildings – Business Realities & Opportunities’ (October 2007), which was presented at an important Paris Conference at the beginning of November, 2007.
This Report looks at what can be achieved in Europe and many other parts of the world – today – using currently available building technologies and systems … IF ‘real’ implementation is taken seriously. Barriers to progress and costs have also been examined.
In the final analysis, however, a properly resourced Indigenous Research Capability, focused on Irish Conditions and Needs, is vitally necessary to drive ‘Real’ Performance and Innovation in this country.
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Post-Bali Leadership from Ireland (and DEHLG !)
A Kyoto II Instrument will be agreed and ratified before the end of 2012. The 1997 UNFCCC Kyoto Protocol must now be seen, therefore, as just the beginning of a long-term process which will last until the end of the century. Some Necessary Direction and a large pinch of Ethical Leadership are urgently required to properly re-position Ireland in this Process.
The following Post-Bali Target Scenario for Ireland is presented for your consideration:
- Ireland should set 1990 as the Benchmark/Base Year for All Kyoto Greenhouse Gases ;
- Statements of Measurement and Calculation Uncertainty should be fully transparent (nationally, and at EU level), and made at every stage of Ireland’s Kyoto Compliance ;
- The EU’s Objective of a 30% Reduction in Greenhouse Gases by 2020, compared to 1990, is the Relevant Short Term Target (refer to Paragraph 31 of the German Presidency Conclusions from the E.U. Council’s Brussels Summit on 8th and 9th March 2007) ;
- As our ‘Real’ Performance, under Kyoto I, continues to be so weak and disingenuous … we should not expect to receive as generous an intra-EU burden sharing arrangement as before. Instead, Ireland should adopt the 2020 National Target of a similar 30% Reduction in Greenhouse Gases, compared to 1990 ;
- Our Contingency Target for 2020 should be a 33% Reduction in Greenhouse Gases, compared to 1990. When considering ‘real’ performance in any field of human endeavour, it is usual to include a safety factor in any calculations …. in this case, 3% ;
- Ireland’s Recourse to the Use of Carbon Sinks and Kyoto Mechanisms in meeting the 2020 Contingency Target should be restricted to 1/4 of ‘Real’ Performance …
- ‘Real’ Performance (no sinks/mechanisms) – minimum 24% Reduction in Greenhouse Gases by 2020, compared to 1990 ;
- Use of Carbon Sinks and Kyoto Mechanisms – 9% Reduction in Greenhouse Gases by 2020, compared to 1990 (this figure includes the contingency 3%) ; and
- As the Construction Sector (when properly identified) should share more of the national burden than, for example, Agriculture …. its Target should be a 40% Reduction in Greenhouse Gases by 2020, compared to 1990. Remember the range of reductions which were initially proposed at Bali …. 25-40% ?
- Part 1 of SDI’s Submission for the Irish Construction Sector (IIEA Climate Change Project, Sectors Sub-Group – June 2007) stressed the great need to properly restore the Construction Sector’s Infrastructure. Otherwise, this Sector will not be able, in reality, to reach any Energy Performance Targets … low or high. Of course, what will eventually appear on paper, or as a computer print-out, is an entirely different matter !
However, having been able to access information about the recent WBCSD Research Project, and using it as a valid substantiation … it then became possible to deal with the issue of Energy Performance Targets for All Buildings (new, existing and those of historical, architectural and cultural importance) more aggressively.
Enclosed, please also find Part 2 of SDI’s Submission for the Construction Sector (IIEA Climate Change Project, Sectors Sub-Group – November 2007).
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Ireland’s Climate Change Strategy ?
1. Ireland’s Current ‘Real’ Situation with Regard to Kyoto (I) Compliance should be clearly understood by the Irish Public. Using the recently issued European Environment Agency (EEA) Report 5/2007: ‘Greenhouse Gas Emission Trends & Projections in Europe 2007 – Tracking Progress Towards Kyoto Targets’, we have extracted just a few snippets of interesting information (enclosed) …
- Instead of 1990, Ireland has chosen 1995 as the Base Year for HFC’s, PFC’s & SF6 ;
- Ireland’s Per Capita greenhouse gas emissions are nearly the worst in the EU-27 ;
- Ireland’s Per GDP greenhouse gas emissions are far too high ;
- Ireland’s ‘Real’ Distance-To-Target (no sinks/mechanisms) is very bad.
Ireland is still grimly grasping on to a ‘Business as Usual’ Approach. This is actually being reinforced by the relevant Institutions of the State, who insist on merely Playing with Numbers … and then publishing Cosmetic Public Relations Brochures for consumption in Ireland and, unfortunately, on the wider European and International Stages.
2. The following National Policy/Strategy Documents & Legislation should directly relate to one other, and their implementation should be tightly co-ordinated …
- National Sustainable Development Strategy ;
- National Climate Change Strategy ;
- National Climate Change Adaptation Strategy ;
- National Spatial Strategy ;
- National Development Plan ;
- National Public Procurement Law.
Not only have some of the above not yet even been drafted, but others are unacceptably inadequate, outdated and/or fundamentally flawed. And the synergies which would normally accrue from co-ordinated implementation are being lost.
3. The World Business Council for Sustainable Development has identified Buildings as one of the five main users of energy where ‘megatrends’ are needed to transform global energy efficiency in the immediate short term, and so meet the daunting challenge of Climate Change Adaptation. They account for 40% of primary energy (primary energy includes the energy required to generate, transmit and distribute electricity, as well as energy directly consumed on site) in most developed countries, and consumption is rising.
Nothing less than a Complete Cultural Shift will be necessary throughout this Sector, beginning with all research and design disciplines and extending right across to any person who works on a construction site or has any part to play in managing, maintaining or servicing a building.
Yet, Irish Construction is not presented as a Coherent Sector anywhere in National or European Greenhouse Gas Databases.
Separate Strategies are urgently required to greatly improve the energy performance of:
- Existing Buildings … onto which many energy efficiency measures can be successfully grafted, but they will not be cheap ;
- Buildings of Historical, Architectural or Cultural Importance … the integrity of which must be protected ; and
- New Buildings, which must therefore carry the major burden.
4. Raising the (General) Awareness of Irish Society regarding Climate Change and Mobilizing People and Organizations for (Effective) Action are two entirely different concepts. Which concept is informing Strategy Development within the DEHLG ?
A €15 m. Marketing Campaign, spread over 4-5 Years and including the ‘Change’ WebSite (!?!?), will not mobilize anyone … to do anything.
5. Your proposals concerning Necessary Building Energy Efficiency Improvements to be included in the Revised Technical Guidance Document L are inadequate. Part L should be applicable to ALL New Buildings.
It has also been insufficiently emphasized in public discussions/consultations concerning this issue that any proposed Building Energy Efficiency Improvements must take place in a context of stringent control during construction (by a sufficient number of competent Local Authority Building Controllers and/or Independent Technical Controllers) and rigorous post-construction energy performance monitoring (using long wave infra-red thermal imagery, in conjunction with building external fabric air seepage tests). Follow-up observation of post-occupation building energy performance will also be required.
This is the one – and only – means of …
- tweaking Computer Software Tools so as to produce more realistic outputs ; and
- obtaining reliable construction-related energy performance data and statistics.
Please Note Well: Without suitable references to the use of long wave infra-red thermal imagery (essential, if working at ambient temperatures – short wave, if working at high temperatures) in Section 5, the Revised TGD L will be absolutely meaningless !!
Because of wasteful patterns of building management and/or use – even in the most energy efficient building – we would also stress that far more attention should be paid to the concept of Intelligent Energy Efficiency Management.
6. We strongly urge you, in accordance with the 2007 Bali Action Plan, to rapidly advance development of the National Climate Change Adaptation Strategy, and to ensure that it is properly implemented.
7. We call for the creation of an adequately resourced Sustainable Development Commission with the necessary legal mandate, independence and technical expertise to monitor – in an integrated, continual and proactive manner – Ireland’s mitigation and adaptation performance in relation to the adverse effects of climate change. We also call for a New Social Partnership for Sustainable Development & Climate Change Adaptation. Addressing Climate Change must be considered an integral element of Sustainable Development Policies.
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At Sustainable Design International … we continue to find, in everyday practice, that the most challenging barriers to Policy Implementation are Institutional – lack of proper horizontal policy integration in Public Authorities, and antiquated approaches to management in Private Organizations. At every level, the concept of Sustainable Human & Social Development is poorly understood.
Should you have any questions or comments, please contact me at your convenience.
Yours sincerely,
C.J. Walsh, etc., etc.
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Carbon Monoxide (CO) Protection in Building Habitable Spaces
Carbon Monoxide (CO) is an odourless, colourless and toxic gas. Because it is impossible to see, taste or smell the toxic fumes, CO can kill you before you are aware it is in your home. At lower levels of exposure, CO causes mild harmful effects which are often mistaken for the flu (influenza). These symptoms include headaches, dizziness, disorientation, nausea and fatigue. The effects of CO Exposure can vary greatly from person to person depending on age, overall health and the concentration and length of exposure. Source: Environmental Protection Agency (EPA), USA.
Recent tragic deaths from CO Poisoning have occurred in Ireland … not only in the home, but also in a hotel.
Sources of Carbon Monoxide (CO) … unvented kerosene and gas space heaters; leaking chimneys and furnaces; back-drafting from furnaces, gas water heaters, wood stoves, and fireplaces; gas stoves; generators and other gasoline powered equipment; automobile exhaust from attached garages; and tobacco smoke. Incomplete oxidation during combustion in gas ranges and unvented gas or kerosene heaters may cause high concentrations of CO in indoor air. Worn or poorly adjusted and maintained combustion devices (e.g., boilers, furnaces) can be significant sources, or if the flue is improperly sized, blocked, disconnected, or is leaking. Car, truck, or bus exhaust from attached garages, nearby roads, or parking areas can also be a source. Source: EPA, USA.
If there is a fuel burning / heat-producing appliance in any habitable space, in any building … and if you have not done so already … you must do something NOW to check that you are protected effectively from CO Poisoning. Shift your ass !
In order to improve energy conservation and efficiency in buildings … direct, natural ventilation from the exterior is still being actively discouraged … and buildings are becoming more tightly sealed, during construction or major refurbishment, to prevent unintended air seepage. Generally, this has been causing a serious increase in Building Related Ill-Health (also known as ’Sick Building Syndrome’) … much of which is still going un-reported.
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BRIEF CHECKLIST – IMMEDIATE ATTENTION
1. Check that there is sufficient, clear, direct natural ventilation in any habitable space which contains a fuel burning / heat-producing appliance. Next … Check that the terminal unit / outlet of the flue coming from that appliance is not blocked. Then … Check the route of any flue from the appliance. If, for example, a flue passes through another habitable space … that space must also be properly ventilated.
2. Check that all fuel burning / heat-producing appliances are ‘fit for their intended use’ (this must be shown !), are working properly … and that they are regularly serviced by people who are competent to do so. Paperwork is not a reliable indicator of competence ! Remember the problems with FÁS !?!
3. Do not confuse Carbon Monoxide Detectors with Smoke Detectors ! Only install a dedicated Carbon Monoxide (CO) Detector for the task of detecting Carbon Monoxide. And … that Detector must be shown to be ‘fit for its intended use’. Read the writing on the outside of the box carefully … and then read all of the instructions inside the box !
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With regard to the issue of Carbon Monoxide (CO) Poisoning in Ireland … Statistics Gathering is not reliable. National Legislation concerning the installation of Carbon Monoxide Detectors in buildings should have been introduced many years ago … but this has not yet happened. Furthermore … don’t hold your breath waiting for this much-needed legislation. Based on past performance, technical and administrative officials in our relevant authority having jurisdiction, i.e. the Department of Environment, Heritage & Local Government (DEHLG), will prefer to wait before acting until similar legislation is introduced in Britain (England & Wales).
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I will just describe what I have done in my own house … in the kitchen …
[Smoke Detectors are separately linked into a monitored security and fire warning system.]
In every room where a fuel burning / heat-producing appliance is located … a Carbon Monoxide (CO) Detector is installed. In the kitchen, for example, the Detector is fixed on the wall … at about head height, when sitting down at a table (appropriate for the normal pattern of use there) … and at a distance of approximately 2 metres from the natural gas kitchen range. Control of direct, natural ventilation to the appliance is active … meaning, it always receives attention. The usual kitchen clutter, e.g. clothes ‘waiting’ for ironing, etc., is never allowed to cover or block the Detector. Everybody in the house understands the purpose of this product.
Colour photograph showing a battery-operated Ei Electronics Carbon Monoxide (CO) Detector, Model Ei206D, fixed (tamper proof) to the kitchen wall. Two of the hanging decorative plates are from France and Turkey. As for the third plate ... does anyone remember the Willow Pattern ? Photograph taken by CJ Walsh. 2011-01-12. Click to enlarge.
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About the performance of the Carbon Monoxide (CO) Detector in the event of a ‘real’ CO Leakage … I am comfortably assured, as I have known the EI Company in Shannon since the mid-1980′s. At that time, I was the first architect in Ireland to install smoke detectors in any local authority housing scheme … and EI gave great technical back up and support, for which I am still very grateful. I might add that those same smoke detectors were installed against the wishes of the local fire department. A report on the whole test installation process was later presented, by Dr. M. Byrne, Engineering Manager of EI, to an International Fire Conference in Dublin.
The particular Carbon Monoxide (CO) Detector shown in the photograph above is a battery-operated Model Ei206D. There are no heavy, smoke sealed fire-resisting doorsets in the house … so the sound level of the distinct alarm / warning signal [85 dB(A) minimum at 3 metres] is more than adequate. A few years ago, this was an expensive item to buy ! Now, however, CO Detectors are widely available … and at a more reasonable price.
Very Importantly … Ei Electronics have also developed a range of products – Solutions for All – which are suitable for use by People with Activity Limitations … http://www.eielectronics.com/ei-electronics/special-needs
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Harmful Health Effects Associated with Carbon Monoxide (CO) Inhalation … at low concentrations: fatigue in healthy people and chest pain in people with heart disease. At higher concentrations: impaired vision and co-ordination; headaches; dizziness; confusion; nausea. Can cause flu-like symptoms which clear up after leaving home. Fatal at very high concentrations. Acute effects are due to the formation of Carboxyhaemoglobin (COHb) in the blood, which inhibits oxygen intake. At moderate concentrations: angina, impaired vision, and reduced brain function may result. At higher concentrations: CO Exposure can be fatal. Source: EPA, USA.
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Health Service Executive (Ireland) Factsheet
January 2011
Carbon Monoxide (CO) Poisoning – A Guide for GP’s & Other Medical Professionals
Click the Link Above to read and/or download PDF File (375kb)
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EU Parliament’s URBAN InterGroup – SDI An Official Partner
2010-11-23: By e-mail from Brussels, dated 2010-11-04 … we have received some good news !
Sustainable Design International (SDI) has been registered … amongst a small number, relatively speaking, of diverse European Organizations having an interest in Urban Planning & Development … as an Official Partner of the European Parliament’s URBAN InterGroup ( http://urban-intergroup.eu/ ).
The URBAN InterGroup focuses on topics related to the Sustainable Development of Urban Areas … and consists of 70 Members of the European Parliament (MEP’s), representing most E.U. Member States.
Check out the InterGroup’s New Newsletter …
Issue No.1 – October 2010
EU Parliament’s URBAN InterGroup Newsletter 1
Click the Link Above to read and/or download PDF File (2.78 Mb)
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New SDI Report on Climate Change Adaptation – Comments ?
This is the HomePage of my Technical Blog … but on a separate WebPage (see the toolbar above), I have been slowly building content, with links to related sources of information, on the subject of a CIB Working Commission 108 International Climate Change Project, which is about to enter its final important stage.
When published in the spring/early summer of next year … 2011 … the CIB W108 Report: ‘Sustainable Climate Change Adaptation in the Built Environment’ will comprise 2 Parts:
I - International Synthesis on Sustainable Climate Change Adaptation.
II - National Perspectives on Sustainable Climate Change Adaptation.
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Today, 18 November 2010 … I uploaded onto that separate WebPage the National Report for ‘IRELAND’, which will appear in Part II of the CIB Publication. I am the person who drafted this report … and it has not been an easy task ! You will see that much attention is paid to institutional and implementation issues.
I now invite comments on the National Report … any comments … from those with a particular interest in the subject … and from the general public.
Comments should arrive here no later than Monday, 20th December 2010 … pretty please !
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Before commenting upon the National Report, however, it would be useful if you also took a glance at the following three relevant documents …
- Ireland’s 5th National Communication (NC5) under the 1992 United Nations Framework Convention on Climate Change, dated 3 March 2010 ;
- UNFCCC In-Depth Review of Ireland’s 5th National Communication (NC5), dated 2 November 2010 ;
- EU WHITE PAPER – Adapting to Climate Change: Towards a European Framework for Action … European Commission Communication COM(2009) 147 final, dated 1 April 2009.
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2009 EU White Paper – ‘Introduction’ (Page 3, first three paragraphs)
Climate change increases land and sea temperatures and alters precipitation quantity and patterns, resulting in the increase of global average sea level, risks of coastal erosion and an expected increase in the severity of weather-related natural disasters. Changing water levels, temperatures and flow will in turn affect food supply, health, industry, and transport and ecosystem integrity. Climate change will lead to significant economic and social impacts with some regions and sectors likely to bear greater adverse affects. Certain sections of society (older people, people with activity limitations, low-income households) are also expected to suffer more.
Addressing climate change requires two types of response. Firstly, and importantly, we must reduce our greenhouse gas emissions (GHG), i.e. take mitigation action … and secondly, we must take adaptation action to deal with the unavoidable impacts. The EU’s recently agreed climate change legislation puts in place the concrete measures to reach the EU’s commitment to reduce emissions to 20% below 1990 levels by 2020 and is capable of being amended to deliver a 30% reduction if agreed as part of an international agreement in which other developed countries agree to comparable reductions and appropriate contributions by economically more advanced developing countries based on their responsibilities and capabilities. However, even if the world succeeds in limiting and then reducing GHG emissions, our planet will take time to recover from the greenhouse gases already in the atmosphere. Thus, we will be faced with the impact of climate change for at least the next 50 years. We need therefore to take measures to adapt.
Adaptation is already taking place but in a piecemeal manner. A more strategic approach is needed to ensure that timely and effective adaptation measures are taken, ensuring coherency across different sectors and levels of governance.
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2009 EU White Paper – The Proposed EU Framework: Objectives & Action (Page 7, #3)
The Objective of the EU’s Adaptation Framework is to improve the EU’s resilience to deal with the impact of climate change. The framework will respect the principle of subsidiarity and support overarching EU objectives on sustainable development.
The EU’s framework adopts a phased approach. The intention is that phase 1 (2009-2012) will lay the groundwork for preparing a comprehensive EU Adaptation Strategy to be implemented during phase 2, commencing in 2013.
Phase 1 (2009-2012) will focus on four pillars of action:
1) building a solid knowledge base on the impact and consequences of climate change for the EU ;
2) integrating adaptation into EU key policy areas ;
3) employing a combination of policy instruments (market-based instruments, guidelines, public-private partnerships) to ensure effective delivery of adaptation ; and
4) stepping up international co-operation on adaptation.
For phase 1 to be a success … the EU, national, regional and local authorities must co-operate closely.
The proposals set out in this paper cover actions to be taken in the first phase and are without prejudice to the future structure of the EU budget and to the current and future multi-annual financial framework.
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IRELAND – Part II National Report for CIB W108 Climate Change Project
In the spring of 2007, the Department of Environment, Heritage & Local Government (DEHLG) – Ireland’s statutory Authority Having Jurisdiction (AHJ) – published the ‘National Climate Change Strategy 2007-2012′. This document can be accessed and downloaded at … http://www.environ.ie/en/Environment/Atmosphere/ClimateChange/ It is of concern to note, however, that ‘Climate Change’ related content is not easy to find on this WebSite ! Comprehensive Enabling Climate Change Legislation, which this Department, and the Irish Government, initially promised for Easter 2010 … and then June 2010 … has, at the time of writing (mid-November 2010), still not made an appearance in the Dáil (Ireland’s Parliament) !
The Department of Environment, Heritage & Local Government (DEHLG) lacks strong and competent political direction and the institutional capacity to effectively co-ordinate and oversee the implementation of National Climate Action. For this reason, closer scrutiny of its activities will be required from the Dáil Committee System.
Contrary to current practice … Foreign Development Aid should not be used to obtain any sort of domestic or in-country credit for Ireland’s National Climate Change Strategy !
Specifically concerning Climate Change Adaptation … the following is stated on Page 45 of the 2007-2012 National Climate Change Strategy Document …
‘As part of a comprehensive policy position on climate change, the Government is committed to developing a national adaptation strategy over the next two years. This strategy will provide a framework for the integration of adaptation issues into decision-making at national and local level.’
The DEHLG does not, however, intend to publish a National Climate Change Adaptation Strategy until 2013 (Ireland’s NC5).
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Climate Change Action in Ireland – Summary
Ireland’s Climate Action to date, i.e. effective Climate Change Mitigation and Adaptation Implementation, has been laboriously slow and lethargic. It may best be characterized as ‘Business as Usual’, combined with some ‘Cosmetic Tinkering at the Edges’ as the need arises … the universal excuse, almost a mantra, being that “the competitiveness of the national economy must not be impaired”. National Performance has been guided by an official policy of exploiting to the maximum all of the UNFCCC Kyoto Protocol’s Flexibility Mechanisms while, at the same time, showing a stark indifference to Climate Adaptation … an over-reliance on Marketing Campaigns in the public media as opposed to mandatory implementation on the ground … and a preference for ‘Soft’ Performance Estimation on paper/computer monitor rather than the more painful ‘real’ performance calculation, which would generate reliable data and statistics to be managed by Ireland’s Central Statistics Office, in co-ordination with EuroStat in Luxembourg.
Despite the importance of the Construction Sector in Ireland and Europe … and its very large adverse impacts on regional and local climate … a significant barrier to concerted Sectoral Climate Action exists because ‘construction’ is not yet identified as a separate Sector, by either the Environmental Protection Agency (Ireland) or the European Environment Agency (Copenhagen) … in National and European Greenhouse Gas (GHG) Emission Databases. Furthermore, our systems of governance and institutional organization, at both levels, do not appear to have the capacity … either to understand or to manage an effective response to the climate challenges created by the Sector.
Climate Change Mitigation Efforts are failing in Ireland; the current economic downturn merely camouflages that unpalatable fact. Therefore, the necessary corrective actions described in this National Report fall under the heading of ‘Climate Change Adaptation’.
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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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2009 Camberwell Fire – Today’s Fire Engineering Challenges
In Ireland, it is rarely the case that there is an opportunity to practice Rational, Evidence-Based Fire Engineering … and to apply its Principles in a manner which is both professional and project-specific. The grim reality of everyday fire consultancy revolves around playing ‘cat and mouse’ with current national building and fire regulations/codes … with ‘cost effectiveness’, i.e. to achieve a defined objective at the lowest cost, or to achieve the greatest benefit at a given cost … being the real, hidden driver behind such dangerous games ! Who wants to hear that the Irish Fire Safety Certification System is little more than a charade … an elaborate, resource consuming paper exercise … made all the more meaningless because Part B: ‘Fire Safety’ (of the Second Schedule to the 1997 Building Regulations, as amended) is isolated from a necessary and vital consideration of the other Parts, particularly Parts A: ‘Structure’; D: ‘Materials & Workmanship’; K: ‘Stairways, Ladders, Ramps & Guards’; and M: ‘Access for People with Disabilities’ ?
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Colour photograph showing an external view of Lakanal House, Sceaux Estate, Camberwell, London (GB) ... after the Fatal Fire which occurred at 16.19 hrs, on 3rd July 2009. The fire was caused by a faulty television set, and resulted in the loss of 6 lives, with 15 residents and 1 firefighter left injured. London Fire Brigade was required to assist the evacuation of a further 40 building occupants to safety. Along with the serious loss of life, and the large number of injured people ... over 90 families had to vacate their flats.
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Discussing the Principles of Fire Engineering … and elaborating on the significant differences between the limited Fire Safety Objectives of legal regulations/codes … and the much broader range of Fire Engineering Design Objectives intended to fully protect social wellbeing and the interests of clients/client organizations, i.e. to properly protect their asses and their assets, in the event of a fire … is a constant, tortuous, but rewarding, struggle. Masochism does help !
However, the 2009 Fire in a High-Rise Flat Complex at Camberwell, London (GB) … from just looking at the photograph above and reading available information about the spread of fire internally … raises some challenging fire engineering issues for building designers, property managers and construction organizations.
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1. Reliability of People Strategies in a Fire Emergency ?
In spite of the People Strategies elaborated in current Fire Codes/Regulations/Standards … it is totally and utterly irresponsible to advise people to wait in their own flats/apartments during a fire incident, or to develop fire safety strategies based on this approach … unless the confidence level (of ‘Competent Persons’ in Control … managers, designers and builders … of the flat/apartment complex) with regard to the following aspects of construction is very high …
- reliability of both passive and active fire protection measures ;
- reliability of fire compartmentation (see below) ;
- reliability of not just the building’s structural stability, but also its serviceability, during the fire and for a minimum period of time afterwards, i.e. the ‘cooling’ phase.
Competent Person: A person capable of making sound value judgements in the area of professional endeavour in which he/she possesses profound knowledge, understanding and practical experience.
Fire Codes/Regulations/Standards, wherever or whatever their origin, are NOT Infallible … and it is unbelievably mind-boggling, and sad, to witness a blind and unquestioning faith in such documents !
Looking beyond the headline figure of 6 Fatalities in the 2009 Camberwell Fire … adequate attention should also be focused on the 16 Injured … comprising building occupants and firefighters … the lengthy disruption of community wellbeing resulting from the fire … 90 Families had to be re-located … and, of course, the tremendous amount of direct and indirect damage to property and the environment. And, I wonder … how did the more vulnerable occupants … and there may also have been visitors present in the complex at the time … cope in this emergency situation ?
This is why Fire Safety, Protection and Evacuation for All must be a Priority on any ‘Sustainability’ Agenda.
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2. Independent Technical Control of AHJ Construction ?
I have said this before, but it is worth repeating here again … Self-Regulation Is No Regulation ! Surely this lesson has been burnt into our souls, following the recent scandals, financial and otherwise, in Ireland ? National and Local Authorities Having Jurisdiction (AHJ’s) … Government Departments & Agencies, Semi-State Organizations, a myriad of Qwangos, the Office of Public Works and Local Authorities are complacent, careless and stubborn concerning proper compliance with even the minimal performance requirements specified in fire regulations, codes and standards.
The 2005 & 2008 National Institute of Standards & Technology (USA) Reports on the 9-11 WTC Incident in New York presented us with some stark language … and a set of important Recommendations which must be heeded …
‘ NIST recommends that such entities be encouraged to provide a level of safety that equals or exceeds the level of safety that would be provided by strict compliance with the code requirements of an appropriate governmental jurisdiction.
To gain broad public confidence … NIST further recommends that as-designed and as-built safety be certified by a qualified third party, independent of the building owner(s). The process should not use self-approval for code enforcement in areas including interpretation of code provisions, design approval, product acceptance, certification of the final construction, and post-occupancy inspections over the life of the buildings.’
[2005 NIST Final Report on WTC 1 & 2 Collapses - Recommendation No. 25]
Later posts, here, will examine the individual NIST Recommendations in more detail.
However … many individuals and organizations, with vested interests, are still trying to discredit and/or ignore the Recommendations contained in the 2005 & 2008 NIST Reports on the WTC 9-11 Incident. British Standard BS 9999:2008 is a typical case in point … a document which is slowly seeping into the marrow of the Irish Fire Establishment. The complete and abject failure to consider any of the NIST Recommendations during the long development of this British Standard, or even to reference the Reports in the Standard’s Bibliography … was an inexcusable and unforgivable technical oversight. The result was … and remains … a sloppy, crassly inadequate, deeply flawed and discriminatory national fire safety standard. The British Public deserves far better !
At this stage … reluctantly … I must invite the Chair of British Standards Institution Committee FSH/14, Mr. David B. Smith, to seriously re-consider his position.
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3. Fire Resistance, Compartmentation & Fire-Induced Progressive Collapse ?
Every person participating in the design, construction, management or operation of a building, no matter how simple or complex, must have a working knowledge and proper understanding of the Fire Engineering Principle of Fire Compartmentation:
The division of a building into fire-tight compartments, by fire and smoke resisting elements of construction, in order …
- to contain an outbreak of fire ;
- to prevent damage, within the building, to other adjoining compartments and/or spaces ;
- to protect a compartment interior from external fire attack, e.g. fire spread across the building’s facade or from an adjacent building ;
- to minimize adverse, or harmful, environmental impacts outside the building.
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BUT … But … but … buildings are no longer designed and constructed, today, as they were in the 18th or 19th Centuries …
In a fire situation, Fire-Induced Progressive Collapse may commence before any breach of ‘integrity’ occurs in the boundary of such a Fire Compartment, i.e. the building compartment of fire origin.
Fire-Induced Progressive Collapse: The sequential growth and intensification of distortion, displacement and failure of elements of construction in a building – during a fire and the ‘cooling phase’ afterwards – which, if unchecked, will result in disproportionate damage, and may lead to total building collapse.
… which is related to, but distinguishable from …
Disproportionate Damage: The failure of a building’s structural system … (i) remote from the scene of an isolated overloading action ; and (ii) to an extent which is not in reasonable proportion to that action.
Structural Fire Engineering: Those aspects of fire engineering concerned with structural design for fire, and the complex architectural interaction between a building’s structure and fabric, i.e. non-structure, under conditions of fire and its aftermath.
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AND … And … and … a designer of a Sustainable Building will want to utilize … in order to conserve energy … natural patterns of air movement for heating or cooling. This means that it will be necessary to have gaps between elements of construction which are continuously open … in direct conflict with the Principle of Fire Engineering just quoted above !
What happens when this sort of conflict … or lack of resolution (!) … occurs in modern, highly energy-efficient construction projects ? At the final stages of approval/certification … the Fire Prevention Officer will insist on following the outdated prescriptive approach in his/her rulebook. In other words, he/she will illegally apply the guidance text of Technical Guidance Document B as if it were prescriptive regulation. Fire Compartmentation will be uncompromisingly slapped onto ‘unresolved’ areas of a completed building design … to achieve the limited Fire Safety Objectives of Building Regulations … and the fire safety related construction will probably be badly executed, anyway, because the un-supervised sub-contractors of sub-contractors of sub-contractors couldn’t care less if it goes one way or the other ! The outcome is … nobody wins !!!
In Sustainable Building Design, therefore, Fire Resistance (a ‘passive’ protection concept) must not only be extended to consider a complementary relationship with ‘active’ fire protection concepts, but be stretched … ‘intelligently’ … to embrace the concept of ‘non-construction’ …
Building Sterile Space (Fire): An open space of sufficient and appropriate extent which is designed to retain an exceptionally low level of fire hazard and risk, and is ‘intelligently’ fitted with a suitable fire suppression system – in order to resist and control, for a specified time during a fire, the advance of heat, smoke and flame.
Fire Resistance: The inherent capability of a building assembly, or an element of construction, to resist the passage of heat, smoke and flame for a specified time during a fire.
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END
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