Building Energy Rating

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 & Necessary Sectoral Infrastructure (IV)

2009-03-14:  The Construction Sector Comedy of Errors continues without intermission …

 

On Tuesday last, 2009-03-10, I attended a Conference in Dublin Castle: ‘Energy Efficiency in Historic(al) Buildings’, organized by the Department of the Environment, Heritage & Local Government (DEHLG) and the Irish Georgian Society.  Boys and girls … we are in trouble … flat, uninspiring presentations from our beloved DEHLG policy makers.  Missing … any wider context of required energy efficiency targets across the whole of the built environment … or views and solutions from anywhere else beyond our two little islands (Ireland & GB) on the periphery of Europe.  The approach taken to this important subject was “let’s just jump in, and see what we can do”.  What a day !

 

[Note: Thanks also to the DEHLG … Ireland still has no National Climate Change Adaptation Policy.]

 

That same morning, on Tuesday, an Opinion Piece: ‘Research Hub Benefits All’ appeared in The Irish Times (page 13), written by no other than Mr. Kieran McGowan, Chairperson of CRH.  He was full of suggestions about research in Ireland, and was most happy to support the proposed research alliance between University College Dublin (UCD) and Trinity College Dublin (TCD).  However, a quick visit to the CRH Holding Company WebSite is both relevant and informative.  There, you will learn that the Company operates in 35 countries, employing approximately 93,500 people.  Entering the key words/phrases … ‘research’, ‘construction research’, and even ‘building research’ … into the site search engine yields nothing of value … that’s right … nichts, nada, niente, zilch, zero !   With all the window dressing about Corporate Social Responsibility (CSR), etc, etc … the principal ‘value’ in CRH still remains short term ‘shareholder value’.  If it looks interesting, gobble it up.  Why waste money on a Research Division ? … which should be located in Ireland !

 

 

Yesterday, 2009-03-13, another Article appeared in The Irish Times (bottom of page 5): ‘Ireland Closer to Kyoto Emissions Target Due to Economic Slump’, by Mr. Harry McGee, IT Political Staff (?).  The Environmental Protection Agency (EPA) Press Release which generated this newspaper article was released on Wednesday, 2009-03-12, at 17.59 hrs. in the evening.

 

The 19-Page EPA Report: ‘Ireland’s Greenhouse Gas Emission Projections 2008-2020’ was issued on the same day as the newspaper article – 2009-03-13.  Excellent media management !

 

These three different texts fail to examine, or even discuss, the following issues …

 

         How many € Millions and € Millions belonging to the Irish Tax Payer are being spent, and will be spent into the far future, on buying this country out of trouble … because of the abject failure to meet our responsibilities under Kyoto I (up to 2012), and the Real EU 2020 Target of -30% GHG Emissions on 1990 levels (assuming there will be an agreement in Copenhagen, next December, on a Post-2012 Kyoto II Instrument).  This has always been the EU Target.  See Paragraph 31, German Presidency Conclusions of the Brussels European Council (8 & 9th March 2007).

 

         Having seen the numbers and range of assumptions which underpin the EPA’s GHG Emission Projections up to 2020 … how Reliable are those projections ?   Where are the critical Statements of Uncertainty ?

 

         Who are the Individuals who sat on their fat, over-paid asses throughout the last 10-15-20 years, and allowed this country to fall into such a haphazard state ?   Would any of these individuals be the same people who are now preaching sermons on ‘responsible’ GHG Emission Compliance … and still foisting upon us Voluntary Codes of Practice and Compliance Schemes, Ineffectual National Marketing Campaigns, Feather Light Regulation, and Press Releases which obscure what is really happening ?

 

Do you see any parallels with current events in the Irish Financial Sector ?

 

         Can the Irish Construction Sector be expected to meet any Real Performance Targets (e.g. Proper Building Energy Rating Labelling, Meaningful GHG Emission Reductions, Serious Energy Efficiency Improvements, whatever … ) – as distinct from Theoretical Performance on paper – without a Very Necessary Sectoral Infrastructure capable of shaping suitable responses to those targets, and ensuring that they are implemented ?

 

 

 

As already discussed in an earlier Post … a Complete Cultural Shift in the Irish Construction Sector is essential.  So, let me give you a small flavour of what we need to do …

 

 

1.  Construction Data & Statistics:

 

Ireland does not currently possess a comprehensive National Construction Database.  No reliable statistics can be presented with regard to building or construction-related performance in 1990, or 2005.  No coherent projections, therefore, can be made for the years 2010, 2012, 2020 or 2050 … under any futures scenario.

 

The Central Statistics Office (CSO) gathers construction-related Economic Data.  Energy Ireland (SEI) Databases are not reliable.

 

Construction is not identified as a separate Sector, by either the Environmental Protection Agency (Ireland) or the European Environment Agency (Denmark), in European Greenhouse Gas Emission (GHG) Databases.

 

 

 

2.  A Concerted Programme of Infrastructure Restoration:

 

         Re-establish and adequately resource an Independent National Institute for Spatial Planning & Construction Research (formerly known as An Foras Forbartha) in Ireland, having joint responsibility with the CSO for maintaining a reliable National Construction Database.

 

Construction Research & Innovation must be given a high national priority !   

 

The National Institute must establish close working relationships with the relevant European Union Institutions, particularly EuroStat in Luxembourg.

 

[By ‘independent’ … I mean at a long, long, long arm’s distance away from the Department of the Environment, Heritage & Local Government (DEHLG).]

 

         Re-establish and adequately resource an Independent and Fully Accredited National Construction Testing & Development Complex.

 

         Re-Format, Revise & Horizontally Integrate the National Building Regulations.

 

The existing format is both limited and seriously flawed.  For discussion in a later Post.

 

         Adequately resource the Irish National Accreditation Board (NAB), and closely monitor the quality of its work.

 

         Adequately resource the National Standards Authority of Ireland (NSAI) and ensure that Ireland participates vigorously in the European Standards Organizations and ISO (International Standards Organization).

 

         Adequately resource an Independent Irish Agrément Board (IAB), and closely monitor the quality of its work.

 

[By ‘independent’ … I mean at a long arm’s distance away from the National Standards Authority of Ireland (NSAI).  These two organizations were supposed to have been separated a few years ago anyway.]

 

         Adequately resource awareness raising and Institutional Capacity building for Sustainability and Climate Change Adaptation in the Department of the Environment, Heritage & Local Government (DEHLG), Energy Ireland (SEI) and the Construction Industry Federation (CIF).

 

         Adequately resource awareness raising, Re-Training and Re-Education for Sustainability and Climate Change Adaptation at all levels in the rest of the Construction Sector, including All (Professional) Design Disciplines and All Construction Organizations.

 

 

 

3.  Initial Construction Quality:

 

Post-completion repairs and/or system retrofitting always involve compromises, are costly and are rarely anywhere near being 100% effective.  Ensure Proper Initial Construction Performance through robust inspection of buildings during construction … checking that all relevant legislation has been complied with and that construction products have been approved, i.e. properly shown to be ‘fit for their intended use (in the location of use)’, etc.

 

         Adequately resource, with Staff (e.g. building controllers, inspectors, administrative, legal), Monitoring Equipment (e.g. sound meters, long wave infra-red cameras, etc.) and Technical Support (e.g. training, library facilities, access to research) … all Building Control Authorities in the country.

 

Introduce a fully Integrated (including Part B of the Building Regulations) and Mandatory Inspection Scheme on all Construction Projects, at the following Construction Stages …

 

Foundations ;

Drainage ;

Ground Floor Construction ;

Super-Structure (above Radon Resisting Membrane) … inspections to take place at a level no higher than first floor ;

Roof.

 

Such an Inspection Scheme must operate uniformly across the country.  Piecemeal variations and maverick procedures operated by National Authorities Having Jurisdiction (AHJ’s) or Individual Local Authorities cannot any longer be tolerated.

 

 

 

4.  Consumer Protection:

 

         Establish an Independent and Comprehensive National Building Insurance Scheme.

 

Self-Regulation by the Architectural and Legal Professions offers merely the ‘appearance’ of protection to the Irish Consumer.

 

The current system of Royal Institute of the Architects of Ireland (RIAI) / Law Society ‘Opinions on Compliance with Building Regulations’ is inadequate … and offers no protection to the Irish Consumer.  The phrase ‘substantial compliance’ is much misunderstood and widely abused.

 

         Introduce and adequately resource the discipline of Independent Technical Controller.  He/she must be independent from Construction-related Organizations, the Building Design and Legal Professions … Local Authorities … and any other National Authorities Having Jurisdiction (AHJ’s).

 

         Introduce a Mandatory Building Completion Certification System.

 

Before any Building can be occupied, a Certificate of Building Completion Performance, and an Accompanying Report, must be issued by an Independent Technical Controller.  The System will include an independent evaluation of compliance with relevant building legislation and a thorough examination of ‘real’ construction performance.

 

Building Completion Documentation can be designed to include …

         a Fire Safety Certificate, which is issued only after adequate monitoring of the actual fire safety related construction ;

         a Disability Access Certificate, which is issued only after adequate monitoring of the actual access related construction ;

         a Building Energy Rating (BER) Label ;

         a Sustainability Impact Assessment (SIA) ;

         etc., etc.

 

 

 

[Many of the above ideas have been incorporated in the 2008 Institute of International & European Affairs (IIEA) Publication: The Climate Change Challenge, which presents a strategic overview of Irish Climate Change Policy.]

 

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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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BER Certificates, Energy Efficiency & Climate Change (II)

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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BER Certificates, Legislation & Thermal Comfort (I)

2009-02-20:  The recent comment submitted by Mr. Robin Evans regarding the use of Infra-Red Thermography as an aid to BER Assessment … and the high level of confusion and misinformation in the marketplace, which I have now had an opportunity to examine more closely … have forced me to conclude that a series of posts on BER Certificates would be good for the system – ‘my’ system !

 

There are many pieces in this jig-saw puzzle, but the final picture is wonderful … please believe me.

 

 

Before I start to assemble anything, however, a few small details …

 

         Infra-Red Thermography.  This is a valuable technical aid during any Energy Survey of any Building.  It is remarkable how much information can be gathered by a good, high-resolution Infra-Red Camera.  But, it must be used competently …  Because we are working in ambient temperature conditions, i.e. between -10OC and +30 OC, it should be a Long Wave Infra-Red Camera (≈ 8-12 microns).  The temperature difference between the inside of the building and the exterior should be at least 10 degrees C … it would be better with 15 degrees C.  The Camera Operator should be fully familiar with the operation of the Camera and its associated computer software, etc … and he/she should know what they are looking at.  In other words, some sort of architectural background is essential … not only are images taken outside the building, but they are also taken inside the building !   Any Camera Work should be done after dark.  It is not necessary to do a midnight to 4 o’clock in the morning shift … 8 o’clock in the evening until midnight is perfectly fine.  By the way, none of this work can be done in just 30 minutes.  Finally, Infra-Red Work is best carried out, in Ireland, during the Heating Season, i.e. the months of November through to March.  Depending on the year, it may be possible to squeeze in the end of October and the beginning of April.

 

In the old days, I used to work as part of a Multi-Disciplinary Team of 4 People (not all males !), comprising a Civil Engineer, a Physicist/Expert in Measurement, an Engineering Technician with a background in Social Science, and myself as Architect/Fire Engineer/Technical Controller.  They were great days !

 

 

Robin … in order to provide this service for the owner of a typical suburban, semi-detached house … €100 (Euros) is a little on the low side, even as a ‘lost leader’.

 

And … the Irish Public are indeed blissfully unaware of the efficacy of Infra-Red Thermography.  The ‘powers that be’ in Ireland, i.e. the Department of the Environment, Heritage & Local Government (DEHLG), Energy Ireland (SEI) and the Construction Industry Federation (CIF), are not at all interested in the ‘real’ energy performance of buildings.  They have a vested interest in not being interested.  Suddenly … the image of an ostrich, with head deeply embedded in sand, floods my mind …

 
Colour Clip Art Image of an Ostrich, with head deeply embedded in sand. Meanwhile, in the background, an hourglass signals that time is running out !
Colour Clip Art Image of an Ostrich, with head deeply embedded in sand. Meanwhile, in the background, an hourglass signals that time is running out !

  

         BER Certificates & EU/National Legislation.  Mr. Charlie McCreevy, Ireland’s EU Commissioner, during one of his many ‘direct, pragmatic and neo-liberal’ talks in Dublin, used the following magnificent phrase in relation to the national implementation of European Union Legislation in the different EU Member States … ‘National Gold Plating and Divergent Implementation’ … some important words to remember !   However, I learned this valuable lesson myself a long, long time ago.

 

Irish National Legislation:  Statutory Instrument No. 666 of 2006: European Communities (Energy Performance of Buildings) Regulations 2006.

 

These Regulations may be unconstitutional.  A prime example … Section 23 (1) states that a person authorised by Energy Ireland (SEI) under the Regulations … ‘may enter, inspect and examine a building or any part of a building for the purpose of forming an opinion as to whether or not a BER Data File or BER Certificate issued for the building, or part of the building, is warranted’.  In relation to a private, single-occupation dwelling house … this provision is entirely unacceptable !

 

The Register of BER Assessors on the SEI WebSite is not reliable.

 

Because of ‘national gold plating and divergent implementation’ in Ireland, it is necessary to be familiar, also, with the originating EU Secondary Legislation.

 

European Union Legislation:  EU Directive 2002/91/EC of the European Parliament and of the Council, of 16 December 2002, on the Energy Performance of Buildings.

 

Both pieces of legislation can be downloaded from the SDI WebSite … here.

 

 

         Thermal Comfort in Buildings.  The starting point for any discussion about this subject should be an International Standard, which is also the European Standard and the Irish National Standard … ISO 7730  Moderate Thermal Environments – Determination of the PMV and PPD Indices and Specification of the Conditions for Thermal Comfort.

 

This Standard establishes the following important general principle … and is also critical in relation to people with activity limitations who use/occupy/visit buildings: Man’s/Woman’s Thermal Sensation is mainly related to the thermal balance of his/her body as a whole.  This balance is influenced by his/her physical activity and clothing, as well as the environmental parameters: air temperature, mean radiant temperature, air velocity (i.e. draughts) and air humidity.

 

Air Temperature, alone, is definitely not an Indicator of Thermal Comfort in a building.

 

 

         Technical Control of Construction.  The 2005 & 2008 NIST Reports on the 9-11 WTC Incident have presented us with some stark language … ‘NIST urges state and local agencies to rigorously enforce building codes and standards since such enforcement is critical to ensure the expected level of safety … unless they are complied with, the best codes and standards cannot protect occupants, emergency responders, or buildings.’

 

With regard to Private Construction in Ireland … Building Control Authorities in Ireland are, purposefully, not sufficiently resourced to be ‘effective’.  See my earlier Post, dated 2009-02-12.

 

With regard to Public Construction in Ireland … self-regulation is no regulation !  Government Departments, the Office of Public Works and Local Authorities can, far too often, be complacent, careless and/or stubborn concerning compliance with even the minimal performance levels specified in building regulations, codes and standards.

 

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Quality of Irish Construction – Unacceptable ?

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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