Statutory Instrument No 666 of 2006 – European Communities (Energy Performance of Buildings) Regulations 2006

Unheeded Fire Hazards in New Energy Efficient Buildings !!

2012-03-29:  The relentless pressure, within the European Union (EU), to bring a greater measure of stability to imported energy supplies … to reduce our overall use of energy … to be far more efficient in the ways we consume those lesser amounts of energy … to find cleaner sources of energy to replace oil, gas, and especially coal … to comply with ambitious targets on climate change mitigation … are all pointing in one direction with regard to design and construction.  We are forced to super-insulate new buildings !

Without many people realizing it, however, we change how fire behaves in a highly insulated building … especially when insulation materials are part of the interior finishes, not carefully buried within the construction.  [Even the old Building Bye-Laws in Dublin City permitted a cavity in a masonry wall up to 150mm wide !]   And, as usual, Building and Fire Regulations are slow to catch up with these important architectural developments.

Let me show you an example of a basement car park in a new hospital (which shall remain nameless !) … where a serious ‘fire’ problem has been festering since it was opened, and occupied, a few years ago.

This hospital could be anywhere in Europe …

Colour photograph showing the basement car park in a hospital. Click this photograph, and the photographs below, to enlarge.

Colour photograph showing the basement car park in a hospital. Click this photograph, and the photographs below, to enlarge.

The ceiling height in this car park is low … approximately 2 metres above floor level.  The ceiling comprises a 6mm off-white calcium silicate board of limited combustibility (for the techies out there – this board is not ‘incombustible’, and it is not ‘non-combustible’) … above which is a 40mm rigid phenolic thermal insulation board … all fixed to the underside of a concrete floor slab.

This phenolic insulation board is very efficient … and during the normal course of events, its job is to stop the loss of heat from the hospital wards and other areas above.  A cold concrete floor is also very uncomfortable for people, i.e. hospital staff, having to walk around on it for long periods.

Because the insulation board is efficient, and it is fixed to the underside of the floor slab … in a fire situation, let’s say that a fire starts in a car … the heat from that fire will be reflected by the insulation board back downwards.  The result:  the fire will be encouraged to spread much more quickly to neighbouring vehicles.  And so, in a very short time, we will have a much larger fire … and a much more intense fire … which will be far more difficult to control and extinguish, when the fire services eventually arrive on the scene.

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There are a Number of Twists in This Story …

     1.  For all sorts of normal reasons, there are service penetration openings in the car park ceiling shown above (some small and some large), especially in a hospital which is highly serviced … the overall approach to fire and smoke sealing in this new building is not the best … and workmanship is poor …

… which, together, all mean that it will be easy for fire and smoke to spread upwards into the hospital wards and other areas … in the event of a fire emergency.

In a hospital, not everybody is alert and mobile.  It will be difficult to evacuate some people … and it will be nearly impossible, because of their health condition, to evacuate others.  In order for a fire engineering strategy of horizontal evacuation to a ‘safer’ part of the same building to be successfully put into effect during an emergency … it is imperativethat the level of passive protection from fire and smoke provided is high … much higher, here, than in the case of an average office building, for example.  AND … it is criticalthat this high level of protection from fire and smoke is reliable.

In this new hospital building … the photographic evidence clearly shows that both of these criteria have not been met.

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     2.  Another twist in the story concerns the rigid phenolic thermal insulation board used in the car park ceiling … which, as the evidence also shows, is exposed to direct view in many places …

In a short, brochure-type document produced by the European Phenolic Foam Association (EPFA): ‘Phenolic Foam Insulation – The Ultimate Insulation System for the Construction & Building Services Industry’, the following is stated with regard to the fire performance of this material …

‘ Toxic gas emission from phenolic foam is generally limited to carbon dioxide and carbon monoxide with very low levels of other gases.’

However, in a report produced by the National Research Council of Canada: ‘Toxicity and Smoke Aspects of Foamed Plastic Insulation – An Annotated Bibliography’ … the following abstracts can be found …

  • Toxicity of Off-Gases from Phenolic Rigid Foam

‘ A reference sample of phenolic rigid foam was evaluated for toxicity of off-gases, using various test conditions in the NASA-USF-PSC toxicity screening test method.  Test results show that the response of this material to the various test conditions is similar to that exhibited by the majority of other materials previously evaluated by this method.  That is, animal response times generally decreased with increasing fixed temperature, and with increasing airflow rate under rising temperature conditions.  The authors suggest that formaldehyde is one of the toxicants present although the amount of CO produced at 600°C or higher was enough to be lethal by itself.

  • Toxicity of Off-Gases from Thermal Insulation

‘ Toxicity test data on the off-gases from various thermal insulation materials are presented in this paper.  Under rising temperature without forced airflow test conditions, phenolic foams exhibited the shortest times to death, while polyisocyanurate, polyurethane and polystyrene foams exhibited the longest times to death.  The introduction of airflow significantly reduced time to death, apparently due to a higher degree of oxidation and more rapid delivery of toxicants.  The authors conclude that under the particular test conditions, plastic thermal insulations appear to exhibit less toxicity than cellulosic board and cellulose insulation, with polyimide and phenolic foams being the exceptions.

  • Relative Flammability and Toxicity of Thermal Insulation

‘ Relative flammability and relative toxicity data are presented for 30 samples of thermal insulation materials.  There appears to be no inherent, necessary compromise between flammability and toxicity in the selection of materials.  Cellulosic and plastics insulations appear to represent significantly different combinations of flammability and toxicity hazards, and require different approaches when planning and designing applications.  Polyurethane foam appeared to be significantly less toxic and slightly less flammable than wood and other cellulosic materials.  Polyisocyanurate foam seemed to be more toxic than polyurethane foam but still less toxic than the cellulosic materials.  Polystyrene foam exhibited the longest time to death while phenolic foam showed the second shortest time to death among the group of rigid foams evaluated.

  • Carbon Monoxide Production from Overheated Thermal Insulation Materials

‘ Carbon monoxide yields were obtained for selected thermal insulation materials.  The data are presented and discussed in this paper.  Among the rigid foamed plastics, phenolic gave the highest yield of CO under a rising temperature and no airflow test conditions.  Polyurethane foams based on propoxylated aromatic amino polyol appeared to produce less CO than polyurethane foams based on propoxylated trimethylolpropane polyol.  Under fixed temperatures of 800°C without airflow test conditions, similar results were obtained for the rigid foamed plastics.’

  • Toxicity of Pyrolysis Gases from Phenolic and Isocyanurate Rigid Foams

‘ Special reference samples of phenolic and isocyanurate rigid foams were evaluated for toxicity of pyrolysis gases, using 6 different test conditions of the USF toxicity screening test methods.  Under rising temperature conditions, phenolic foam appeared to be consistently more toxic than the isocyanurate foam.  CO level appears to be the factor, which is twice as high from the phenolic foam.  The temperatures corresponding to the times to death indicate that the toxicants were evolved below 500°C for phenolic and below 640°C for isocyanurate.  These are in agreement with that of the University of Pittsburgh (UP) data.  At a fixed temperature of 800°C, there appeared to be no difference in toxicity between the phenolic and isocyanurate foams, although the former tended to produce more carbon monoxide.’

  • Toxicity of Pyrolysis Gases from Phenolic, Isocyanurate and Polystyrene Rigid Foam Insulation

‘ Samples of phenolic, isocyanurate, and polystyrene rigid foam insulation were evaluated for toxicity of pyrolysis gases, using four different test conditions of the toxicity screening test method developed at the University of San Francisco.  The test conditions were 200 to 800°C rising temperature and 800°C fixed temperature, each without forced airflow and with 1 L/min airflow.  On the average over these four particular test conditions, phenolic foam appeared to exhibit the greatest toxicity and polystyrene foam appeared to exhibit the least toxicity.

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As already discussed in an  earlier post , dated 2011-01-13 … we know that Carbon Monoxide (CO) is an odourless, colourless and toxic gas … and because it is impossible to see, taste or smell the toxic fumes, CO can kill before you are aware it is there.

So … it will be easy for Fire, Visible Smoke and Carbon Monoxide to spread upwards into the hospital wards and other areas of this building … in the event of a fire emergency.

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This Hospital’s ‘Fire’ Problem & Its Solution

The ‘fire’ problem in this hospital has been allowed to fester for a number of years because the issues shown in the photographs above are either inadequately addressed … or not addressed at all … in Ireland’s Technical Guidance Document (TGD) B … a document which is intended merely to present some supporting guidance for operating Part B: ‘Fire Safety’, in the 2nd Schedule of the Building Regulations.

Unfortunately, all parties directly responsible for this hospital debacle are under the very mistaken impression that the guidance in Technical Guidance Document B is prescriptive regulation.  This is a major error !   Furthermore … TGD B is fundamentally flawed … and it is particularly inadequate when the building type is a health facility.

To Correct This ‘Fire’ Problem … a Fire Suppression System should immediately be installed in the basement car park.  At the same time, if not before … ALL Service Penetration Openings in the concrete floor slab should be properly sealed so that, during a fire incident, the passage of fire and smoke and CO into building spaces above the slab will be prevented.  And … the quality of workmanship, on site, must be high !

An appropriate number of Carbon Monoxide Detectors should be installed in the hospital wards and other areas above the concrete floor slab.

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The ‘Institutional’ Problem

The procedure of having to submit so-called Compliance Reports with applications for Fire Safety Certificates, in Ireland, only confirms … and reinforces … the very mistaken impression in everybody’s minds that the guidance in Technical Guidance Document B is prescriptive regulation.

In the case of a different hospital … let me give you an example of a text contained in one such Compliance Report … submitted to an Irish Local Authority, sometime during 2004 …

Single Steps at Final Exit Doors

It is noted that Clause 1.4.3.4 of TGD-B is ambiguous vis-à-vis steps located on the line of final exit doors, i.e. as opposed to a condition where there is a step beyond the line of a door.  Accordingly, it is reasonable and appropriate to make reference to the current England and Wales Approved Document B (2000 Edition) for guidance on this issue in so far as Technical Guidance Document B is based on an early draft of the Approved Document.  It is noted that the UK AD-B in Clauses 6.15 and 6.21 specifically allow single steps at final exits provided they are located on the line of the doorway in question.  Furthermore, the recently issued Northern Ireland Technical Bulletin E (1994) also allows such steps, subject to the riser not exceeding 180mm.  On the basis of the foregoing, single steps are considered acceptable at the final exit doors subject to the riser not exceeding 180mm and the step being located on the line of the door.

This is mindless, incompetent nonsense … and it was accepted by the Local Authority.

How often, anymore, does anybody encounter a step … 180mm high, or of any height … at the front entrance to a new building ?   Building designers have finally understood the message that new buildings must be accessible-for-all … and a single step, in any situation, is a trip or a fall accident waiting to happen.  Now imagine the situation where people are attempting to evacuate an average office building, for example, during a fire emergency … and they encounter a single step at the final fire exit !?!   Now really stretch your imagination … and imagine where people are trying to evacuate a hospital !!??!!

FUBAR !!

The System is not only entirely dysfunctional … it is corrupt !

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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.

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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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.

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.

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.

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.

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.

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.

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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BER Certificates – A Major Infra-Red Survey in Paris (VIII)

2009-12-19:  Still recovering from the shock of the 2009 Copenhagen Accord (!!!) … something has to be said before talking about Paris or France again.  It’s funny looking back, now, to last November …

Wednesday Evening (2009-11-18) – Soccer World Cup Play-Off – Ireland v France – Stade de France 

I admit it … I was not a believer before the match … and was expecting that Ireland would be blown out of the stadium.  However … at the kick-off, I found myself glued to the television.  It was a blatant, intentional and obvious handball by Thierry Henry.  There might be a simple explanation … perhaps, he is a fan of Gaelic Football and somebody gave him a present of a DVD last Christmas !

Après le Match en Irlande 

There is nothing so boring as listening to the English go on … and on … and on … and on … about that 1986 Diego Maradona Goal.  Pay-back time for Las Malvinas ?   In Ireland, let’s stop the whinging … and move on.  We can be a great team – not just a good team – at the next European Championships in 2012 !

Anyway … back to Paris

Colour photograph of a Multi-Storey Paris Apartment Block (1975-81).  Click to enlarge.

Colour photograph of a Multi-Storey Paris Apartment Block (1975-81). Click to enlarge.

Early last spring (2009) … as a Special Project in preparation for Copenhagen … some very intelligent people in the Office of the City Mayor (who understand the value, but also the limitations, of marketing campaigns !) … organized that 500 typical buildings of the city, from each of the different historical periods up to the present day, would be surveyed using Infra-Red Thermography.  To complement the building surveys … an aerial survey of the whole city was also carried out.  The results will be placed in the public domain … for all in Paris to see … during 2010.

Colour thermograph of the Same Multi-Storey Paris Apartment Block (1975-81).  Parts of the building where most heat is being lost are shown in red.  An accompanying vertical surface temperature scale is also shown on the right of the image.  Click to enlarge.

Colour thermograph of the Same Multi-Storey Paris Apartment Block (1975-81). Parts of the building where most heat is being lost are shown in red. An accompanying vertical surface temperature scale is also shown on the right of the image. Click to enlarge.

 

 

 

 

 

 

The following Project Description was contained in the French Design e-Newsletter ‘Maison à Part’ (www.maisonapart.com), dated Friday 23rd October 2009.  This description is more interesting and informative than a similar description on the City Mayor’s WebSite (www.paris.fr) !

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Une Thermographie Parisienne Instructive … 

Colour photograph of a Multi-Storey Paris Block of Flats (1945-67).  Click to enlarge.

Colour photograph of a Multi-Storey Paris Block of Flats (1945-67). Click to enlarge.

A l’occasion des Journées Parisiennes de l’Énergie et du Climat du 22 au 25 Octobre 2009, la ville de Paris présente pour la première fois les résultats de la campagne de photographies en infrarouge de la capitale.  Cette carte thermographique permet d’analyser les bâtiments énergivores.

 

 

Colour thermograph of the Same Multi-Storey Paris Block of Flats (1945-67).  Parts of the building where most heat is being lost are shown in red.  An accompanying vertical surface temperature scale is also shown on the right of the image.  Click to enlarge.

Colour thermograph of the Same Multi-Storey Paris Block of Flats (1945-67). Parts of the building where most heat is being lost are shown in red. An accompanying vertical surface temperature scale is also shown on the right of the image. Click to enlarge.

 

 

A six semaines de l’ouverture de la Conférence des Nations-Unies sur le Changement Climatique à Copenhague, la ville souhaite montrer son engagement dans la lutte contre le réchauffement climatique.  C’est tout l’objet des deuxièmes journées parisiennes énergie et climat, qui se tiendront du 22 au 25 Octobre au Palais Brongniart à Paris.  L’occasion également de découvrir pour la première fois, lors d’une exposition, une carte thermographique des immeubles parisiens.  Réalisée sur 500 bâtiments de style et d’âge différents, elle permet de se rendre compte de toutes les déperditions d’énergie et de trouver ainsi les solutions adéquates.  Chaque Parisien pourra ainsi découvrir sur une carte géante de Paris, son immeuble et sa performance énergétique.

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Des Prises de Vue Révélatrices … 

Colour photograph of a Large Paris Residence (Before 1850).  Click to enlarge.

Colour photograph of a Large Paris Residence (Before 1850). Click to enlarge.

Mais d’où viennent ces photos ?   “La nuit du vendredi 6 mars 2009, l’ensemble du territoire parisien a été thermographié depuis un avion” est-il expliqué.  “La thermographie aérienne est une technique qui permet de mesurer la température à la surface des toitures à l’aide d’une caméra infrarouge et d’analyser la déperdition de chaleur des constructions.”   Ainsi, “plus le toit apparaît rouge, plus il est chaud, ce qui signifie qu’une partie de l’énergie dépensée pour chauffer le logement est en fait perdue dans l’atmosphère.”  Une campagne de prises de vue des façades à l’aide d’une caméra thermique – l’hiver en début de soirée, lorsque le thermomètre est en dessous de 5°C – réalisée par la ville permet de compléter l’ensemble.

“Chaque grande période de construction à Paris est analysée sous l’angle architectural et thermique, avec des préconisations de travaux pour chacune” précise les organisateurs de l’exposition.

 

Colour thermograph of the Same Large Paris Residence (Before 1850).  Parts of the building where most heat is being lost are shown in red.  An accompanying vertical surface temperature scale is also shown on the right of the image.  Click to enlarge.

Colour thermograph of the Same Large Paris Residence (Before 1850). Parts of the building where most heat is being lost are shown in red. An accompanying vertical surface temperature scale is also shown on the right of the image. Click to enlarge.

 

 

Courant 2010, un Site Internet représentant chaque type d’immeuble devrait être mis en place, grâce auquel chacun pourra “tirer des préconisations générales” en matière d’économies d’énergie pour son propre immeuble, même si “cette photographie ne remplace pas un diagnostic thermique”, a précisé à l’AFP l’adjoint à l’environnement de la Mairie de Paris, Denis Baupin.  Le Site montrera quatre photos de façade par bâtiment, la couleur rouge symbolisant les pertes d’énergie les plus importantes.

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Harmonized Indicators of Building GHG & Energy Performance

[ BER Certificates (VII) : UNFCCC COP-15 : CIB W108 – Climate Change and the Built Environment ]

2009-12-18:  Even before the gatherings of UNFCCC COP-15 & Kyoto Protocol MOP-5 began … some remarkably positive progress on difficult technical issues had already been made at international level.  Hot off the presses … comes an important document from the United Nations Environment Programme (UNEP) Sustainable Buildings & Construction Initiative (SBCI): ‘Common Carbon Metric’ (December 2009), which was specifically prepared for presentation at Copenhagen.

Leading experts from around the world have developed a standardized method of measuring a building’s carbon footprint … allowing greenhouse gas emissions from buildings anywhere in the world to be consistently assessed and compared.  In the case of existing buildings, improvements can also be measured.

This harmonized method for MRV (Measurable, Reportable & Verifiable) GHG Emissions and Energy Use provides the basis for establishing baselines, performance benchmarking, and monitoring building performance improvements.  These activities are, in turn, fundamental in informing international mechanisms for carbon trading, policy development and analysis, and progress reporting on the mitigation of GHG Emissions from buildings.  Policy and decision makers can produce reports from the data collected through these Metrics/Indicators for jurisdictions, regions, large building stock owners, cities or at a national level to form baselines that can be used to set targets and show improvements in carbon mitigation throughout the building sector.

I am pleased to say that Monsieur Jean-Luc Salagnac (CSTB France), Co-Ordinator of CIB Working Commission 108 : Climate Change and the Built Environment, was directly involved in its development …

Colour image showing the cover page of the UNEP-SBCI 'Common Carbon Metric', recently published in December 2009.  Click to enlarge.

Colour image showing the cover page of the UNEP-SBCI ‘Common Carbon Metric’, recently published in December 2009. Click to enlarge.

 UNEP-SBCI ‘Common Carbon Metric’ (December 2009)  for measuring, reporting and verifying (mrv) greenhouse gas emissions and energy consumption of buildings in use.

Click the Link above to read/download PDF File (1.97 MB)

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Recommendations on Implementing the New Harmonized Approach

All research, design and teaching disciplines involved in the European Building Sector … extending right across to any person who works on a construction site or has any part to play in managing, maintaining, servicing or operating a building … should familiarize himself/herself/themselves with the contents of this document.

As soon as practicable … calculation methods, computer software packages, reports, BER Certificates, etc … and working practices generally … should all be revised and updated to take account of this newly harmonized approach.

Whatever the outcome from Copenhagen in December 2009 … in terms of the presentation of priorities … these should now be switched around … with a strong first emphasis being placed on ‘GHG Emissions’ from Buildings … followed by, and secondly, ‘Energy Consumption’ resulting from the Use/Occupation of Buildings.

What is Measured in the UNEP-SBCI ‘Common Carbon Metric’ ?

While all stages of a building’s life cycle produce GHG Emissions, building use accounts for 80-90% of these emissions … resulting from energy consumed mainly for heating, cooling, ventilation, lighting and electric/electronic appliances.  This, therefore, is the stage of the building’s life cycle that is the focus of the ‘Common Carbon Metric’.

The following Metrics/Indicators shall be used to compile consistent and comparable data:

1.  Energy Intensity = kWh/m2/year (kilo Watt hours per square metre per year)

Scope: Emissions associated with building energy end-use defined in Appendix 1 are included; purchased electricity, purchased ‘coolth'(opposite of warmth)/steam/heat, and/or on-site generated power used to support the building operations.  If available, emissions associated with fugitives and refrigerants used in building operations should be reported separately.

If available, occupancy data should be correlated with the building area to allow Energy Intensity per occupant (o) to be calculated = kWh/o/year.

GHG Emissions are calculated by multiplying the above Energy Intensity times the official GHG emission coefficients, for the year of reporting, for each fuel source used (see Appendix 3).

2.  Carbon Intensity = kgCO2e/m2/year or kgCO2e/o/year (kilograms of carbon dioxide equivalent per square metre or per occupant per year)

Note: GHG conversion factors for each fuel type shall be the same as those used under national reporting for flexible mechanisms for the Kyoto Protocol for the six GHG Gases (see Appendix 4).

Why Buildings ?

The environmental footprint of the Building Sector includes: 40% of energy use, 30% raw materials use, 25% of solid waste, 25% water use, and 12% of land use.  While this new document focuses on the scope of emissions related to energy use of building operations (see Appendix 1), future metrics are required to address these other impacts in addition to social and financial impacts.  At this time the UN’s top priority is climate change … and the building sector is responsible for more than one third of Global GHG Emissions and is, in most countries, the largest emissions source.  While 80-90% of the energy used by the building is consumed during the use (or operational) stage of a building’s life cycle (for heating, cooling, ventilation, lighting, appliances, etc.), the other 10-20% (figure varies according to the life of the building), is consumed during extraction and processing of raw materials, manufacturing of products, construction and de-construction.  Furthermore, significant energy is used in transporting occupants, goods and services to and from the building.

The UNEP-WMO Intergovernmental Panel on Climate Change (IPCC) 4th Assessment Report estimated that building-related GHG Emissions reached 8.6 billion metric tons (t) CO2equivalent (e) in 2004, and could nearly double by 2030, reaching 15.6 billion tCO2e under their high-growth scenario.  The report further concluded that the building sector has the largest potential for reducing GHG Emissions and is relatively independent of the price of carbon reduction (cost per tCO2e) applied.  With proven and commercially available technologies, the energy consumption in both new and existing buildings can be cut by an estimated 30-50% without significantly increasing investment costs.  Energy savings can be achieved through a range of measures including smart design, improved insulation, low-energy appliances, high efficiency ventilation and heating/cooling systems, and conservation behaviour by building occupants.

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Buildings of Historical, Architectural & Cultural Importance !

2009-10-08:  Deeply interested … and ‘luuuving’ … a hands-on and direct involvement in the Sustainable Restoration of Buildings which are of Historical, Architectural or Cultural Importance … or even those buildings which are not so important … I am deeply frustrated and angry when I look around at what has happened … and continues to happen … in Ireland … horrible, damaging interventions and alterations of all kinds … too many of which cannot be undone.

Certain guru-like organizations and individuals must be robustly challenged !

Yes … in everyday practice, there are pressures concerning an improvement of energy performance (BER Certificates !) … an improvement of accessibility performance for people with activity limitations (2001 WHO ICF) … an improvement of fire safety performance, etc., etc. … and, in the next few short years, adaptation to climate change will require serious attention.

BUT – BUT – BUT … in dealing with these buildings (a priceless heritage for our children, and their children, which cannot be replaced !) … some absolutely core principles must influence the minds of decision-makers in client and construction organizations, national authorities having jurisdiction, regulators … and, most importantly, the minds and souls of architects and engineers.  (I am wondering … do engineers have souls ?)

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ICOMOSInternational Council on Monuments & Sites / Conseil International des Monuments et des Sites – works for the conservation and protection of cultural heritage places and is the only global, non-governmental organization of its kind.  It is dedicated to promoting the application of theory, methodology, and scientific techniques to the conservation of the architectural and archaeological heritage.  Its work is based on the principles enshrined in the 1964 International Charter on the Conservation and Restoration of Monuments and Sites (Venice Charter).

From practical experience, I have found the 16 Principles of the 1964 Venice Charter to be enormously helpful …

ARTICLE 1    The concept of an historic monument embraces not only the single architectural work but also the urban or rural setting in which is found the evidence of a particular civilization, a significant development or an historic event.  This applies not only to great works of art but also to more modest works of the past which have acquired cultural significance with the passing of time.

ARTICLE 2    The conservation and restoration of monuments must have recourse to all the sciences and techniques which can contribute to the study and safeguarding of the architectural heritage.

ARTICLE 3    The intention in conserving and restoring monuments is to safeguard them no less as works of art than as historical evidence.

ARTICLE 4    It is essential to the conservation of monuments that they be maintained on a permanent basis.

ARTICLE 5    The conservation of monuments is always facilitated by making use of them for some socially useful purpose.  Such use is therefore desirable but it must not change the lay-out or decoration of the building.  It is within these limits only that modifications demanded by a change of function should be envisaged and may be permitted.

ARTICLE 6    The conservation of a monument implies preserving a setting which is not out of scale.  Wherever the traditional setting exists, it must be kept.  No new construction, demolition or modification which would alter the relations of mass and colour must be allowed.

ARTICLE 7    A monument is inseparable from the history to which it bears witness and from the setting in which it occurs.  The moving of all or part of a monument cannot be allowed except where the safeguarding of that monument demands it or where it is justified by national or international interest of paramount importance.

ARTICLE 8    Items of sculpture, painting or decoration which form an integral part of a monument may only be removed from it if this is the sole means of ensuring their preservation.

ARTICLE 9    The process of restoration is a highly specialized operation.  Its aim is to preserve and reveal the aesthetic and historic value of the monument and is based on respect for original material and authentic documents.  It must stop at the point where conjecture begins, and in this case moreover any extra work which is indispensable must be distinct from the architectural composition and must bear a contemporary stamp.  The restoration in any case must be preceded and followed by an archaeological and historical study of the monument.

ARTICLE 10    Where traditional techniques prove inadequate, the consolidation of a monument can be achieved by the use of any modem technique for conservation and construction, the efficacy of which has been shown by scientific data and proved by experience.

ARTICLE 11    The valid contributions of all periods to the building of a monument must be respected, since unity of style is not the aim of a restoration.  When a building includes the superimposed work of different periods, the revealing of the underlying state can only be justified in exceptional circumstances and when what is removed is of little interest and the material which is brought to light is of great historical, archaeological or aesthetic value, and its state of preservation good enough to justify the action.  Evaluation of the importance of the elements involved and the decision as to what may be destroyed cannot rest solely on the individual in charge of the work.

ARTICLE 12    Replacements of missing parts must integrate harmoniously with the whole, but at the same time must be distinguishable from the original so that restoration does not falsify the artistic or historic evidence.

ARTICLE 13    Additions cannot be allowed except in so far as they do not detract from the interesting parts of the building, its traditional setting, the balance of its composition and its relation with its surroundings.

ARTICLE 14    The sites of monuments must be the object of special care in order to safeguard their integrity and ensure that they are cleared and presented in a seemly manner.  The work of conservation and restoration carried out in such places should be inspired by the principles set forth in the foregoing articles.

ARTICLE 15    Excavations should be carried out in accordance with scientific standards and the recommendation defining international principles to be applied in the case of archaeological excavation adopted by UNESCO in 1956.

Ruins must be maintained and measures necessary for the permanent conservation and protection of architectural features and of objects discovered must be taken.  Furthermore, every means must be taken to facilitate the understanding of the monument and to reveal it without ever distorting its meaning.

All reconstruction work should however be ruled out ‘a priori’.  Only anastylosis, that is to say, the reassembling of existing but dismembered parts can be permitted.  The material used for integration should always be recognizable and its use should be the least that will ensure the conservation of a monument and the reinstatement of its form.

ARTICLE 16    In all works of preservation, restoration or excavation, there should always be precise documentation in the form of analytical and critical reports, illustrated with drawings and photographs.  Every stage of the work of clearing, consolidation, rearrangement and integration, as well as technical and formal features identified during the course of the work, should be included.  This record should be placed in the archives of a public institution and made available to research workers.  It is recommended that the report should be published.

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Note on BER Certificates for Historical Buildings in Ireland

Unless and until that magnificent marketing and public relations firm … Energy Ireland (SEAI) … can openly show that the DEAP Software has been properly modified to handle buildings of historical, architectural or cultural importance … and this modification is fully transparent … Building Energy Rating (BER) Certification for these building types must be put on hold.

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BER Certificates – A Proposal for What’s Next ! (VI)

2009-06-08:  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.

 

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BER Certificates & ‘Big Brother’ – 1984 Style ? (V)

2009-04-14:  ‘Big Brother’ has arrived on our doorsteps … not in the style of today’s reality television … but in the George Orwell 1984 style of a generation ago … when 1984 used to be far into the distant future.

 

I wasn’t quite sure, but I thought that some readers … avid followers of Ireland’s BER Soap Opera … might be interested in the contents of a certain Important Notice Regarding BER Certificates (on official headed notepaper) … with the name of Mr. Steven Manek MIAVI, Partner, Douglas Newman Good (estate agents) at the bottom of the page … and dated March 2009 … which was circulated to DNG’s client vendors …

 

” We have now been advised by the Irish Auctioneers and Valuers Institute (IAVI) to contact all our vendor clients and advise them that an officer from one of the local authorities has started visiting estate agents’ offices in the greater Dublin area to inspect BER certificates for properties currently for sale/rent.

 

The IAVI have further advised us that if a certificate is not available the inspector is currently allowing a short grace period for provision of a certificate (even though there is no legal reason for them to do so).  If a certificate is not available within that time frame there is a risk of prosecution thereafter as it is a legal requirement to provide a BER certificate.  The maximum fine for a vendor under the legislation is €5,000.

 

In view of this we wish to formally notify you of your legal obligations and recommend that you obtain a BER certificate for your property as soon as possible.

 

The energy rating of a property must be carried out by a trained and registered SEI Building Energy Rating Assessor (BER Assessor).  We have a panel of assessors that can undertake this certification for you and should you wish us to handle this for you please do not hesitate to contact me.

 

 

Like too many other people … Steven does not seem to have taken the time to read the actual legislation.  Or, maybe he has … which is worse … whatever !

 

The clear intention of this nasty piece of DNG propaganda, however, is to scare the living daylights out of their own client vendors … and to drive them, like lost little sheep into the long spindly arms of their own in-house BER Assessors.

 

 

Hold onto your liathróidí folks !

 

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BER Certificates & Poor Indoor Air Quality (III)

2009-02-27:  Energy Labelling of Industrial Products is an essential means of raising consumer awareness about energy efficiency and conservation.  I like being able to wander into an electrical shop anywhere in Ireland, Italy or Turkey, for example … and to compare the energy performance of different makes of washing machines, dishwashers or fridges … and even of apparently similar products in the different countries.

 

I can easily visualize these small industrial products being brought into a test laboratory, and then being put through their paces.  It is a credible system.

 

This is NOT possible, however, with a building.

 

 

EU Directive 2002/91/EC of the European Parliament and of the Council, of 16 December 2002, on the Energy Performance of Buildings … is a short document of 7 Pages.  Its Preamble takes up slightly more than the first 2 Pages, and there is a 1 Page Annex at the rear.  Its language is clear and straightforward (see the example of Article 4 below).

 

[What I fail to understand is how and why the Irish National Legislation which implements the Directive … Statutory Instrument No. 666 of 2006: European Communities (Energy Performance of Buildings) Regulations 2006 … is so clumsy, awkward and full of flaws … offering us yet another example of failed ‘light-touch regulation’.  It may also be unconstitutional.]

 

 

 

The EU Directive has something important to say about Indoor Air Quality

 

Article 4 – Setting of Energy Performance Requirements

 

1. Member States shall take the necessary measures to ensure that minimum energy performance requirements for buildings are set, based on the methodology referred to in Article 3.  When setting requirements, Member States may differentiate between new and existing buildings and different categories of buildings.  These requirements shall take account of general indoor climate conditions, in order to avoid possible negative effects such as inadequate ventilation, as well as local conditions and the designated function and the age of the building.

 

[Quick flashback to a generation ago … the panic, throughout Europe, to conserve energy in the late 1970’s and early 1980’s led to a dramatic reduction in rates and quantities of direct, natural ventilation to the habitable spaces of buildings.  This, in turn, had an adverse impact on Indoor Air Quality, and led to a sharp rise in Asthma among building occupants.]

 

 

 

In Ireland, today, problems concerning Poor Indoor Air Quality continue to occur … typically during the Winter Heating Season.  There is a natural tendency to keep windows closed and to seal permanent ventilation openings.  Accidental indoor air seepage to the exterior is also being reduced in our newer building stock.

 

Poor Indoor Air Quality, an important factor in relation to building related ill-health (also known as ‘sick building syndrome’), can cause serious health impairments and severely restrict a person’s participation in everyday activities, e.g. work.

 

Symptoms and Signs may include:

         irritation of eyes, nose and throat ;

         respiratory infections and cough ;

         voice hoarseness and wheezing ;

         asthma ;

         dry mucous membrane and skin ;

         erythema (reddening or inflammation of the skin) ;

         lethargy ;

         mental fatigue and poor concentration ;

         headache ;

         stress ;

         hypersensitivity reactions, i.e. allergies ;

         nausea and dizziness ;

         cancers.

 

 

 

The following 2 Performance Indicators of Good Indoor Air Quality, developed with the aim of protecting human health, are recommended:

 

         Carbon Dioxide (CO2) concentrations in a building should not significantly exceed average external levels – typically within the range of 300 to 500 parts per million – but should at no time exceed 800 parts per million ;

 

         Radon Activity (including Rn-222, Rn-220, RnD) in a building should, on average, fall within the range of 10 to 40 Bq/m3 … but should at no time exceed 60 Bq/m3.

 

 

NOTES:

 

The concept of Protecting Human Health is altogether different from the concept of Assessing Risk to Safety.

 

In Ireland, testing for Radon Activity in buildings must take place during the Heating Season, i.e. the months of November through to March.  What is the use of testing during July, for example, when windows will be wide open ?   Who would even think of doing that ?   I wonder.

 

Measurement Uncertainty of the standard Alpha Particle Etched-Track Detector distributed by the Radiological Protection Institute of Ireland (RPII) is as follows:

         under laboratory conditions: …………………… in the order of …… +/- 10%

         under tightly controlled site conditions: …. in the order of …… +/- 20%

         under typical conditions of use: …………….. well in excess of … +/- 30%

 

Unfortunately, until the RPII includes proper statements of Measurement Uncertainty in its Test Reports … our Organization cannot recommend RPII Radon Testing Services, and we will not accept RPII Test Reports as proper evidence of Radon Test Results.

 

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END

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