sustainable design

BER Certificates & Poor Indoor Air Quality (III)

Posted by CJ Walsh

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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BER Certificates, Energy Efficiency & Climate Change (II)

Posted by CJ Walsh

2009-02-23:  The World Business Council for Sustainable Development (WBCSD) has identified buildings as one of the five main users of energy where ‘megatrends’ are needed to transform global energy efficiency in the immediate short term, and so meet the daunting challenge of Climate Change Adaptation.  They account for 40% of primary energy (primary energy includes the energy required to generate, transmit and distribute electricity, as well as energy directly consumed on site) in most developed countries, and consumption is rising. 

                         … 2007 WBCSD Energy Efficiency in Buildings (EEB) Project

 

 

If you find that you are not responding emotionally to that … please leave your computer immediately and take a cold shower !   When you return, check out how far adrift Ireland is – even on paper – in meeting its legally binding 1997 Kyoto Protocol (UNFCCC) responsibilities.  After 2012, the European Union’s 2020 Targets will be in a different league altogether.

 

Let there be do doubt, therefore, that over the next few years … nothing less than a complete cultural shift will be necessary throughout the European Construction Sector – and this very much includes Ireland – beginning with all research and design disciplines and extending right across to any person who works on a construction site or has any part to play in managing, maintaining or servicing a building.

 

 

 

Burden Sharing in the Built Environment

 

Separate Energy Efficiency Strategies will be required to vastly improve the energy performance of:

–         existing buildings … onto which many energy efficiency measures can be successfully grafted … but they will not be cheap, and they will not be 100% effective ;

–         buildings of historical, architectural or cultural importance … the integrity of which must be protected ;   and

–         new buildings, which must therefore carry the major burden.

 

In addition … if we fully value the Agricultural Industry in Ireland, the burden to be carried by New Buildings may have to be far heavier.

 

 

 

Suggested Building Energy Efficiency Targets in Ireland to 2020

 

From the Beginning of 2012, i.e. after an Essential Transition Period involving extensive re-education and up-skilling, accompanied by ‘attractive’ incentives …

–         Require all New Buildings to achieve a Minimum Building Energy Rating (BER) of ‘A1’ … indicating a Primary Energy Consumption less than or equal to 25 kWh/m2/yr.  And require 40% of Primary Energy Consumed to be, directly or indirectly, from Renewable Energy Sources ;

–         Require all Existing Buildings to achieve a Minimum Building Energy Rating (BER) of ‘B1’ … indicating a Primary Energy Consumption less than or equal to 100 kWh/m2/yr.  And require 15% of Primary Energy Consumed to be, directly or indirectly, from Renewable Energy Sources.  Retain Incentive Measures to achieve better performance with regard to energy efficiency and/or renewable energies ;

–         Require Buildings of Historical, Architectural or Cultural Importance to achieve a Minimum Building Energy Rating (BER) of ‘C1’ … indicating a Primary Energy Consumption less than or equal to 175 kWh/m2/yr.  Retain Incentive Measures to achieve better energy efficiency performance.  No legal requirements or incentives with regard to Renewable Energies should apply to Buildings of Historical, Architectural or Cultural Importance.

 

From the Beginning of 2015 …

–         Require all New Buildings to be ‘Positive Energy Buildings’ (see below) ;

–         Require all Existing Buildings to achieve a Minimum Building Energy Rating (BER) of ‘A2’ … indicating a Primary Energy Consumption less than or equal to 50 kWh/m2/yr.  And require a Positive Energy Contribution of 25 kWh/m2/yr to be from renewable Energy Systems installed in the building ;

–         Require Buildings of Historical, Architectural or Cultural Importance to achieve  a Minimum Building Energy Rating (BER) of ‘B1’ … indicating a Primary Energy Consumption less than or equal to 100 kWh/m2/yr.  Retain Incentive Measures to achieve better energy efficiency performance.  No legal requirements or incentives with regard to Renewable Energies shall apply to Buildings of Historical, Architectural or Cultural Importance.

 

 

 

‘Effective’ Technical Control of Construction & Post-Occupation Buildings

 

Any proposed Building Energy Efficiency/Conservation and Renewable Energy Improvements must take place in a legal environment of stringent control during construction (by competent Local Authority Building Controllers and/or Independent Technical Controllers) and rigorous post-construction energy performance monitoring (using Long Wave Infra-Red Thermal Imagery, in conjunction with building roof and external wall Air Seepage Tests).  Observation of post-occupation building energy performance will also be necessary.  Introduce mandatory 5-Yearly Energy Surveying of Buildings.

 

 

 

The Paradigm for New Buildings – A ‘Positive Energy’ Return

 

Primary Energy Consumption is less than or equal to 15 kWh/m2/yr.  Renewable Energy & Heating Systems then contribute a reliable quantity of energy, per year, which covers the following:

–         the Building’s Primary Energy Consumption ;

–         an Energy Efficiency Degradation Factor which takes account of the degradation in energy efficiency normally expected during the life cycle of renewable energy and heating systems installed in the building (the rate of degradation will depend on the quality of maintenance and servicing) … and caused by wasteful patterns of building management and/or use ;

–         the energy consumed by Private Transport associated with the building ;

–         an Energy Return to an Intelligent District or Regional Grid exceeding, by a whole number multiple determined by reference to local conditions, the total energy consumed by the Building (including its Energy Efficiency Degradation Factor) and any associated Private Transport.

 

Uniquely, this more practical elaboration of the innovative concept of Positive Energy Buildings considers life cycle energy efficiency degradation.

 

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Quality of Irish Construction – Unacceptable ?

Posted by CJ Walsh
2009-02-12:   So … Anglo-Irish Bank has been caught – finally – playing with numbers and cooking the books.  And … because of inadequate (i.e. a complete lack of effective) control by the National Financial Regulator, this was regarded as a routine, ‘smart’ transaction by privileged individuals.  “What is the problem ?” … they ask … “no laws were being broken”.

 

Holding firmly onto those thoughts, let us briefly turn our attention to the Construction Sector … and the Energy Performance of Buildings …

 

A new Home Energy Savings (HES) Scheme was recently announced by Mr. Eamon Ryan T.D., Minister of Communications, Energy & Natural Resources … €100 million Insulation Scheme to Benefit 50,000 Homes – Programme Will Create 4,000 Jobs … according to an article in The Irish Times, on Monday 9th February 2009, by Mr. Harry McGee.

 

Reading the Department of Energy’s own Press Release for the Scheme Launch, dated 2009-02-08 … it is evident that public relations consultants, marketing gurus, senior academics (who should know better) and civil servants were involved in producing ‘paper’ numbers to justify and support the miserable grants being offered in the HES Scheme.  Numbers were even presented for ‘Typical Net BER Improvement’ ?!?

 

When the Scheme is eventually up and running, Thermal Insulation Contractors will be required to comply with a voluntary Energy Ireland (SEI) ‘Contractors Code of Practice & Standards and Specifications Guidelines’ (version 1, 2009-02-03) … and SEI may or may not carry out control inspections in order to monitor the quality of their work.  Does all this sound familiar ?

 

 

But … are these paper energy numbers ‘real’ ?   If he thinks so, Mr. Eamon Ryan is living in Alice’s Wonderland !

 

This is a photograph, taken back in 2000, of expanded polystyrene insulation which was badly installed in an external cavity wall … very badly installed !   When the Irish Construction Industry would later enter extreme ‘over-heat’ mode, the quality of typical construction would deteriorate sharply.

 

Colour Photograph of an External Cavity Wall, showing 'Floating' Thermal Insulation (and, in the background, an Inclined Steel Wall Tie which will later facilitate water ingress). Click to enlarge. Photograph taken by CJ Walsh. 2000-01-19.
Colour Photograph of an External Cavity Wall, showing ‘Floating’ Thermal Insulation (and, in the background, an Inclined Steel Wall Tie which will later facilitate water ingress). Click to enlarge. Photograph taken by CJ Walsh. 2000-01-19.

Who can know what is happening inside that cavity when it is all finished and covered up from view ?   Nobody.  Unless, that is, you manage to take an Infra-Red Thermal Image during the next winter heating season – which is far too late to remedy the problem.

 

This is an example of an Infra-Red Thermal Image, taken back in 1998 …

 

Colour Image, with explanatory Text and Horizontal Temperature Bar below, showing the 'Real' Energy Performance of a Building. Click to enlarge. Project Architect: CJ Walsh. Image taken by sub-contractor in 1998.
Colour Image, with explanatory Text and Horizontal Temperature Bar below, showing the ‘Real’ Energy Performance of a Building. Click to enlarge. Project Architect: CJ Walsh. Image taken by sub-contractor in 1998.

 

 

Explaining the Current Context in Ireland …

 

It was 10 Years after the Dublin Stardust Fire Tragedy (February 1981) … before the first legal, National Building Regulations were introduced (December 1991); they became operational during the following summer of 1992.  Around the same time, Building Control Authorities were being established in every Local Authority.

 

Prior to this, legal Building Bye-Laws were operated in just a small number of our major urban centres.

 

Dublin Corporation’s Bye-Laws with respect to the Construction of Buildings, adopted by Dublin City Council on 27th June 1949, were an interesting mix of functional, performance and prescriptive requirements.  An Application, containing detailed construction information, for Building Bye-Law Approval had to be made for every construction project … and I mean ‘every’ project … prior to any construction commencing.  And, ‘every’ project was inspected at the foundation and drainage stages of construction … no exceptions.  The more complex projects were inspected as they progressed further, with special attention being paid, for example, to fire safety related construction.  I know, first-hand, that the surveyors and inspectors in Dublin Corporation’s (as it was then called) Building Control Section had built up a considerable wealth of knowledge and understanding about construction conditions and practices right around the city and suburbs.

 

Anyway … after the introduction of the National Building Regulations, an unwritten national policy was put into action … having as an aim the winding down, and general ‘castration’, of the large, well-established Building Control Sections in Dublin City and County, and Cork.  Meanwhile … in the rush to establish the new Building Control Authorities throughout the rest of the country, it was common to hear of Road Engineers being transferred into the new Control Authorities … usually having little or no experience in dealing with the construction of buildings.

 

Site Inspections under our current system of National Building Regulations are random.  Inspection Statistics produced by the Department of the Environment, Heritage & Local Government (DEHLG) are not reliable.  Building Control Authorities are, purposefully, not sufficiently resourced to be ‘effective’.

 

Commencement Notices, under the National Building Control Regulations, do not have to be accompanied by detailed construction information when being submitted to a Building Control Authority.

 

Fire Safety Certificates, under the National Building Control Regulations, do not involve any Site Inspections – at any stage – by Fire Authorities.

 

 

 

Some Conclusions …

 

The above is a rather long, but simplified, explanation as to why a large number of privileged property developers and shoddy building contractors have been allowed to flourish on Irish Construction Sites without ever understanding the concept of ‘effective’ technical control.  When they do eventually meet this concept, head-on, the level of their resentment can be without limit.

 

Before the recent property crash, did you ever try to present a builder with a Snag List on a new house ?

 

This will also put SEI’s 70% rate of non-compliance into an understandable context.  See my earlier Post, dated 2008-12-12.

 

With regard to BER Certificates … BER Assessors without any sort of architectural background are not competent to assess the construction of existing buildings … and those BER Assessors with an architectural background cannot possibly evaluate, with reliability, the construction of existing buildings without the use, for example, of Infra-Red Thermography and Air Seepage Testing.

 

BER Assessment of Historical Buildings is unsuitable, and not appropriate.

 

An Energy Survey of a Building is an entirely different concept to a BER Assessment.  See our Technical Guidance Note No.95/101(a).

 

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