Ar C.J. Walsh – Consultant Architect, Fire Engineer & Technical Controller – International Expert on Sustainability Implementation + Accessibility-for-All + Fire Safety for All + Sustainable Fire Engineering
2013-09-10: Recently, much ado has been made in the technical press about a New Multi-Storey Office Block in Vienna which has achieved the German ‘Passivhaus’ (Passive House) Standard …
Is There A Problem ?? Yes !!
1. It takes approximately 3 Years of Building Occupation, by ‘real’ people, before the actual performance of a building can be properly monitored and reliably shown. The building is still ‘drying out’ for the first year. It takes at least one to two years of running the complex technologies and systems in today’s buildings … training people how to operate them efficiently and effectively … and fine-tuning and de-bugging as you go along … before everything begins to work together, as originally intended during the building design stage. Then, if all goes well … in the third year of occupation, the careful (i.e. accurate and reliable) monitoring of ‘real’ building performance, by means of portable measuring devices and devices installed within the construction, can commence.
So … what exactly has achieved the German ‘Passivhaus’ (Passive House) Standard … the design intent for the building, or the building’s ‘real’ performance ???
2. Much more fundamentally … achieving this Standard is a good starting point … but in a new building project … It Is Not Enough !
A. Energy Conservation and Efficiency Burden Sharing by Different Building Types
Separate strategies are required to greatly improve the energy performance of:
existing buildings … onto which many energy efficiency measures can be successfully grafted, but it will be difficult work and will certainly not be cheap ;
buildings of historical, architectural or cultural importance … the integrity of which must be protected ; and
new buildings and facilities … which must therefore carry the major burden.
B. Paradigm for New Buildings – A ‘Positive Energy’ Return + Assured Building User Comfort
Primary Energy Consumption should be less than or equal to 15 kWh/m2/yr.
Renewable Energy and Heating Systems should contribute a reliable quantity of energy, per year, which covers the following:
i) the Building’s/Facility’s Primary Energy Consumption ;
ii) an Energy Efficiency Degradation Factor which takes account of the degradation in energy efficiency …
(a) 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
(b) caused by wasteful patterns of building management and/or use ;
iii) the energy consumed by Private Transport associated with the building or facility ;
iv) an Energy Return to an Intelligent District, Local or Regional Grid exceeding, by a multiple of 3 (three), the total energy consumed by the Building/Facility (including its Energy Efficiency Degradation Factor) and any associated Private Transport.
Primary Energy includes the energy required to generate, transmit and distribute electricity, as well as energy directly consumed on site.
User Thermal Comfort = Air Temperature + Mean Radiant Temperature + Air Humidity + Air Velocity, i.e. draughts (ISO 7730).
Adapted to Local Context and Heritage (fr: le Patrimoine – see ICOMOS 2011) … geography, climate (incl. change, variability and severity swings), social need, culture, and economy, etc., etc.
‘Person-Centredness’ is a core value of Sustainable Human & Social Development … an essential principle in Sustainable Design … an indispensable support framework for Sustainability-related Policy and Decision-making … and an invaluable indicator when monitoring Sustainability Implementation.
Why so because ?
It is the mid-1990’s … in the centre of Dublin City.
Imagine, if you will, a very large historical building having a civic, justice-related function … and also an enormous Energy Bill. As described in a much earlier post, dated 2009-02-20, and the series of posts which followed on the subject of Building Energy Rating (BER) … we found that the most effective and practical remedy for this gaping and continuously haemorrhaging ‘energy’ wound was to approach the problem though the building’s users, their perception of thermal comfort, and International Standard ISO 7730.
The ‘real’ reduction in energy consumption, the ‘real’ increase in the building’s energy efficiency, and the ‘real’ improvements in building user / employee comfort and morale … were astounding !
At a 1999 Strasbourg Conference in France … I delivered the following Paper …
These are interesting times; the benefits of modern technology have bypassed and long overtaken the stirring thoughts, visions and catch cries of Architects at the beginning of the 20th Century. However, at this time in Europe, we must now ask ourselves some difficult questions …
“What should be the Design Agenda for the ‘Built Environment’ in the new millennium ?”
“Do we actually understand the ‘real’ needs and desires of ‘real’ people in an inclusive society ?”
It is Sustainable Design – the art and science of the design, supervision of related construction/de-construction, and maintenance of sustainability in the Built Environment – which is currently generating a quantum leap in the forward evolution of a more coherent design philosophy.
Principle 1 of the 1992 Rio Declaration on Environment and Development states …
‘Human beings are at the centre of concerns for sustainable development. They are entitled to a healthy and productive life in harmony with nature.’
Deeply embedded, therefore, within this philosophy is the concept of ‘person-centredness’, i.e. that core design value which places real people at the centre of creative concerns, and gives due consideration to their health, safety, and welfare in the Built Environment – it includes such specific performance criteria as: a sensory rich and accessible (mobility, usability, communications and information) environment; fire safety; thermal comfort; air, light and visual quality; protection from ionizing / electromagnetic radiation; nuisance noise abatement; etc. An important ‘person-centred’ design aid is the questionnaire survey, which is not only a very valuable source of information, but formalizes meaningful consultation between practitioners and end users.
SDI’s Guideline Framework on achieving equality of opportunity and social inclusion, which is based on a strategy produced by Directorate-General V of the European Commission, shows how further essential elements of ‘social wellbeing’ also relate to person-centredness; these include partnership between all sectors of society, consensus, transparency and openness.
This paper explores the rational and legal basis for person-centredness of the Built Environment in Europe. Fieldwork incorporating this innovative approach is also examined. Finally, a body of principles – a European Charter – is outlined which aims to ensure that new construction works, and renovated existing buildings, perform reliably, are adaptable, accessible and responsive, ‘intelligently green’ (French: intelli-verdure), cost-effective and inherently sustainable.
CLIMATE CHANGE ADAPTATION & MITIGATION POLICIES
AND BEFORE developing Climate Change Policies which will have such dramatic impacts on human populations, and their lifestyles, around the globe … perhaps those policies would be more effective, in the ‘real’ world and in the long-term … if we looked at the problem through the ‘eyes’ of people !
It will be worth taking a look at an interesting background paper produced by the World Bank in 2009 … whether you agree or disagree with the following statements …
“A lack of citizen understanding regarding the basics of climate science is an almost universal finding worldwide even though knowledge has increased over time. Especially notable is confusion between the causes of climate change and ozone depletion, and confusion between weather and climate.”
“North Americans know far less about climate change than their counterparts in the developed world.”
“Accurate and complete understanding of information is not a prerequisite for concern.”
“Concern is widespread around the world, but it may also be inversely correlated with the wealth and carbon footprint of a nation, or the socio-economic ‘class’ within a nation.”
“In some studies, more informed respondents reported less concern or sense of responsibility towards climate change.”
“People stop paying attention to global climate change when they realize that there is no easy solution for it. Many people judge as serious only those problems for which they think action can be taken.”
Policy Research Working Paper No.4940 (May 2009) – Kari Marie Norgaard
Click the Link Above to read and/or download PDF File (290 Kb)
This World Bank Working Paper – prepared as a background paper to the World Bank’s World Development Report 2010: Development in a Changing Climate. Policy Research Working Papers are posted on the Web at http://econ.worldbank.org
World Bank Working Paper 4940 (2009) – ABSTRACT …
Climate scientists have identified global warming as the most important environmental issue of our time, but it has taken over 20 years for the problem to penetrate the public discourse in even the most superficial manner. While some nations have done better than others, no nation has adequately reduced emissions and no nation has a base of public citizens that are sufficiently socially and politically engaged in response to climate change. This paper summarizes international and national differences in levels of knowledge and concern regarding climate change, and the existing explanations for the worldwide failure of public response to climate change, drawing from psychology, social psychology and sociology. On the whole, the widely presumed links between public access to information on climate change and levels of concern and action are not supported. The paper’s key findings emphasize the presence of negative emotions in conjunction with global warming (fear, guilt, and helplessness), and the process of emotion management and cultural norms in the construction of a social reality in which climate change is held at arms length. Barriers in responding to climate change are placed into three broad categories: 1) psychological and conceptual; 2) social and cultural; and 3) structural (political economy). The author provides policy considerations and summarizes the policy implications of both psychological and conceptual barriers, and social and cultural barriers. An annotated bibliography is included.
2012-05-31: The International Standard, ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’, was published back in December 2011. A few years before that, however, a decision was taken to link this Standard directly to the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) … specifically referencing Preamble Paragraph (g) and Articles 9, 10 and 11 in its Introduction. Reading the document now, this linkage looks and feels very naturally like an umbilical cord !
ISO 21542 has significantly widened the meaning of the concept ‘Accessibility-for-All’ … a normal evolutionary process. I wonder, though, how many people would ever have considered Good Indoor Air Quality to be on the ‘Accessibility’ Menu ??
Much lower rates of direct fresh air ventilation … and a dramatic reduction in accidental or unintended air seepage from, or into, buildings (depending on local climate conditions) … all driven by a pressing need to conserve energy and to impose greater energy efficiencies on the energy which is actually consumed … are, once again, one of the main causes of serious problems for ALL building users …
Building Related Ill-Health: Any adverse impact on the health of building users – while living, working, generally occupying or visiting a specific building – caused by the planning, design, construction, management, operation or maintenance of that building.
I say “once again”, because we have been here before in Europe … after the oil crises of the 1970’s.
Anyway … I thought that it would be useful to present a relevant extract from ISO 21542 …
B.8 – INDOOR AIR QUALITY (IAQ)
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 ;
dry mucous membrane and skin ;
erythema (reddening or inflammation of the skin) ;
mental fatigue and poor concentration ;
hypersensitivity reactions, i.e. allergies ;
nausea and dizziness ;
These symptoms and signs are present in the population at large, but are distinguished by being more prevalent in some building users, as a group, when compared with others. The symptoms and signs may disappear, or may be reduced in intensity, when an affected person leaves the building. It is not necessary that everyone in a building should be affected before building related ill-health is suspected.
ISO 16814: ‘Building Environment Design – Indoor Air Quality – Methods of Expressing the Quality of Indoor Air for Human Occupancy’ covers methods of expressing indoor air quality (IAQ) and incorporating the goal of achieving good IAQ into the building design process. It also covers ventilation effectiveness, harmful emissions from building materials, air cleaning devices, and heating, ventilation and air conditioning equipment.
The indoor pollutants considered in ISO 16814 include human bio-effluents, which have often been the principal consideration in air quality and ventilation design, but also the groups and sources of pollutants which can reasonably be anticipated to occur in the building during its long life cycle.
These pollutants, depending on the sources present, may include:
volatile organic compounds (VOC’s) and other organics, such as formaldehyde ;
environmental tobacco smoke (ETS) ;
natural radon, consisting of a number of different isotopes, is an invisible radioactive gas, and is found in the soils under buildings, water supplies to buildings and in the air ;
other inorganic gases, such as carbon monoxide (CO), the oxides of nitrogen (NOx), and low-level ozone (smog) which is formed when NOx and VOC’s react in the presence of sunlight ;
viable particles, including viruses, bacteria and fungal spores ;
non-viable biological pollutants, such as particles of mites or fungi and their metabolic products ;
non-viable particles, such as dusts and fibres.
The following Two Performance Indicators of Good Indoor Air Quality, developed with the aim of protecting human health, are recommended:
Radon Activity (incl. Rn-222, Rn-220, RnD) in a building should, on average, fall within the range of 10-40 Bq/m3, but should at no time exceed 60 Bq/m3.
Carbon Dioxide (CO2) concentrations in a building should not significantly exceed average external levels – typically within the range of 300-500 parts per million (ppm) – and should at no time exceed 800 ppm.
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 …
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.
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 imperative … that 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 critical … that 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.
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.‘
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.
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.
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 188.8.131.52 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 !!??!!
The System is not only entirely dysfunctional … it is corrupt !
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 …
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.
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.”
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.
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 !!
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 …
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 … ?
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.
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.
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 !
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.
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.
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.
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).
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’.
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 …
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 !
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 …
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.
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) !
Une Thermographie Parisienne Instructive …
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.
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.
Des Prises de Vue Révélatrices …
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.
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.