Department of the Environment Heritage and Local Government (DEHLG)

BER Certificates & New Improvements to French DPE System

2011-09-15:  Further to my post, dated  8 June 2009 …

On 13 September 2011 … the French Ministère de l’Écologie, du Développement Durable, des Transports et du Logement announced 6 measures to improve their National DPE (Diagnostic de Performance Energétique) System … equivalent to our BER (Building Energy Rating) System in Ireland.

In the context of my earlier post, you will find these improvements interesting …

Colour image showing the recently announced revision to the National DPE (Diagnostic de Performance Energétique) Building Rating System in France. The new system will enter into force on 1 January 2012.

Colour image showing the recently announced revision to the National DPE (Diagnostic de Performance Energétique) Building Rating System in France. The new system will enter into force on 1 January 2012.

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Nathalie Kosciusko-Morizet et Benoist Apparu, Secrétaire d’Etat chargé du Logement, ont présenté, Mardi 13 Septembre 2011, 6 Mesures pour Améliorer et Fiabiliser le Diagnostic de Performance Energétique (DPE).  Pour plus de transparence, une amélioration des méthodes de calcul, une meilleure formation des diagnostiqueurs et un contrôle plus efficace de la profession.

Rendu obligatoire depuis le 1er Janvier 2011 par le Grenelle Environnement, le  Diagnostic de Performance Energétique (DPE)  est amené à jouer un rôle de plus en plus important dans les décisions d’acquisition ou de location de logements.

Un Outil Apprécié des Français

La Performance Energétique des Bâtiments représente un double enjeu: elle permet d’améliorer le pouvoir d’achat des Français par une meilleure maitrise des dépenses d’énergie, et par ailleurs, elle participe à la lutte contre le changement climatique.

[ Aujourd’hui, le secteur du bâtiment représente 42.5 % des dépenses d’énergie.  Il est le plus gros consommateur d’énergie en France parmi l’ensemble des secteurs économiques. ]

Désormais connu du grand public, le dispositif bénéficie d’une image positive auprès des Français puisqu’en Mars 2011, 80% des ménages considèrent la consommation énergétique du logement comme un critère de choix très important, et 60% déclarent que s’ils étaient appelés à mettre leur appartement en vente, ils envisageraient de faire des travaux pour en améliorer la performance énergétique.

« Le DPE a été très rapidement adopté par les Français et est devenu un critère essentiel pour guider leur choix d’acquisition et location de logement.  Il était donc important d’en faire un outil dans lequel ils ont une entière confiance.  Les mesures qui vont être mises en place ont pour but de faire de l’étiquette énergétique un outil de référence incontestable, permettant aux Français d’améliorer leur pouvoir d’achat en évaluant et en maitrisant mieux leur consommation d’énergie » ont souligné les Ministres.

6 Mesures pour une Etiquette Energétique Fiabilisée

Ce programme s’axe autour de 6 mesures portant sur plus de transparence, une amélioration des méthodes de calcul, une meilleure formation des diagnostiqueurs ou encore un contrôle plus efficace de la profession.

     1. Une Meilleure Transparence vis-à-vis des Particuliers:  Le diagnostiqueur devra à présent expliciter les données qu’il renseigne auprès du particulier à travers un relevé détaillé.  Cela permettra au particulier d’être entièrement informé sur la façon dont a été réalisé son document.  La remise d’un document officiel limitera également le risque de DPE ‘frauduleux’.

     2. Amélioration de la Méthode de Calcul:  Pour un résultat plus fiable, il s’agit d’augmenter le nombre de données à analyser afin de faire un calcul plus précis de la performance énergétique.

     3. Utilisation de Logiciels Validés par le Ministère:  Pour un meilleur encadrement des logiciels utilisés, il s’agit de limiter la liste de logiciels autorisés à générer des DPE aux logiciels ayant été soumis à une procédure d’évaluation menée entre 2008 et 2010 par le ministère et l’Agence de l’Environnement et de la Maîtrise de l’Energie (ADEME).

     4. Une Base de Données des DPE sera Mise en Ligne:  Les statistiques permettront, entre autre, de nourrir l’élaboration des stratégies nationales et locales.

     5. Une Montée en Compétence des Diagnostiqueurs, en augmentant le niveau de difficulté des examens.  Jusqu’à aujourd’hui, un seul examen existait, à présent 2 niveaux de difficulté seront mis en place selon la mention (mention « bâtiments d’habitation » ou « tous types de bâtiments » – tertiaires, publics, privés, etc.).

     6. Un Contrôle plus Efficace, avec pour les particuliers, un annuaire des diagnostiqueurs mis en ligne par le ministère, et la mise en place d’une enquête de la Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes (DGCCRF) dans le secteur du diagnostic immobilier dans le cadre de sa mission de protection économique du consommateur …

L’ensemble de ces mesures, qui entreront en vigueur dès le 1er Janvier 2012, permettront l’amélioration d’un outil encore récent, mais dont l’utilité et l’efficacité sont déjà démontrées.

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Disability Access Certificates (DAC’s) in Ireland – Confused ??

2011-09-01:  To say, bluntly, that there is confusion out there … at every level … would be a mild understatement !   Yes, the Disability Access Certificate (DAC) & Revised DAC Process is new … but that cannot explain what is happening … or, more precisely, what is not happening.

BUT … before jumping in at the deep end and examining the existing and operative Part M of the Irish Building Regulations … let me just mention, very briefly, two wider legal ‘niceties’ concerning Accessibility of Buildings for People with Disabilities

     1.  The Black Hole between Building Regulations and Equality Law

The definition of People with Disabilities in the existing Part M is limited.  It is inadequate.  Compare, now, that definition with the definition of Disability in Irish Equality Legislation … which is the complete opposite, being very wide in scope.  A deep chasm exists between the two.  Check each of them out for yourself !   And because few people are aware of this chasm … a better description of that large space might be a Black Hole.

However, the clear consequence of the Black Hole for building owners … and building designers alike … is that the ‘act’ of merely going through the motions with regard to compliance with Part M … and being satisfied with getting ‘the’ piece of paper, i.e. a Disability Access Certificate … will, without any shadow of a doubt, open the building owner to a complaint under Equality Law.  And when a building owner encounters this sort of problem … who will he, or she, hunt down for an explanation ??

Client Organizations beware … prevention is a far better strategy !!   Check out the Level of Accessibility Performance required to avoid complaints under Equality Legislation.

[ You should also consider the following … the Health & Safety Authority in Ireland is doing absolutely nothing to ensure that Workplaces are Accessible … a requirement contained in all of the European Union (EU) Safety at Work Directives and the Irish National Legislation implementing those Directives.  So, also cross check the Level of Accessibility Performance required to comply with Safety at Work Legislation.  Compliance with Part M is not sufficient ! ]

     2.  European Union Ratification of the 2006 United Nations Convention on the Rights of Persons with Disabilities (CRPD)

For a sizeable group of vulnerable people in every EU Member State, the sole route of access to many, if not most, of the Human and Social Rights set down in the 1948 Universal Declaration of Human Rights (UDHR) is the UN Convention on the Rights of Persons with Disabilities (CRPD) … which became an International Legal Instrument on 3 May 2008, and was ratified by the European Union on 23 December 2010.  That is precisely why Accessibility is such a critical component of the 2006 UN Convention !

Articles 31 & 33 of the 2006 UN Convention on the Rights of Persons with Disabilities – together – mandate that Accessibility Implementation is taken seriously … that it is competent and effective … and, most importantly, that independent monitoring and verification is a fundamental part of the process.

Ireland has not yet ratified the UN CRPD.  And, as far as our National Authorities Having Jurisdiction (AHJ’s) are concerned … everything in the garden is beautiful … Ireland is doing just great and nothing much needs to be altered in our laws, administrative provisions or resourcing … to allow Ireland to ratify the Convention, and then properly implement it.  Nothing could be further from the truth !

In Order to Protect your Organization and its many interests … Your Policy and Decision Makers, in Ireland, should study the implications flowing directly from EU Ratification of the UN CRPD … and then, the various Articles of the UN Convention should be examined and properly implemented … insofar as those Articles are relevant to you and your organization’s activities.  See my earlier post, dated 5 February 2011.

To date … the quality of Accessibility Implementation in Irish Buildings has been dreadful !!   For important reasons … which all parties involved should fully understand … this situation is longer acceptable.

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Colour photograph showing the front entrances to dwelling units in a New Inner City Housing Scheme in Dublin ... User Unfriendly ... Inaccessible for Many Vulnerable People in Our Society ... Dreadful Accessibility Implementation ! Photograph taken by CJ Walsh. 2003-09-13. Click to enlarge.

Colour photograph showing the front entrances to dwelling units in a New Inner City Housing Scheme in Dublin ... User Unfriendly ... Inaccessible for Many Vulnerable People in Our Society ... Dreadful Accessibility Implementation ! Photograph taken by CJ Walsh. 2003-09-13. Click to enlarge.

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Disability Access Certificates (DAC’s) & Part M

The submission of sufficient, quality information, i.e. detailed design documentation, at Disability Access Certificate (DAC) Application Stage typically signals the following to an experienced technical controller …

  • The intent of the Applicant, and the Agent(s) acting on his/her/their behalf, with regard to properly and satisfactorily complying with the relevant building legislation, i.e. Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Irish Building Regulations ;  and
  • In the absence of an inspection by the Building Control Authority (BCA) during actual construction … whether or not it is likely that the completed works will match the DAC certified design documentation with regard to Accessibility Performance.

From the beginning, it is necessary to distinguish between Access and Accessibility.

To be written in stone when International Standard ISO 21542 is soon published … the components of Building Accessibility comprise …

  • Approach to the building ;
  • Entry ;
  • Use of the building, its services and facilities ;
  • Egress from the building (during normal conditions) ;
  • Removal from the vicinity of the building (during normal conditions) ;

and

  • Evacuation from the building (during, for example, a fire emergency) ;
  • Safe Movement to a ‘place of safety’ (during, for example, a fire emergency), which is remote from the building.

This is also a useful guideline with regard to segregating those aspects of Accessibility Design which relate to Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Irish Building Regulations, and which should be considered in any application for a Disability Access Certificate (DAC) … and those, after ‘and‘ … which relate to Part B: ‘Fire Safety’, and which should be considered in every application for a Fire Safety Certificate (FSC).

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The 2000 Building Regulations (Amendment) Regulations … Statutory Instrument No. 179 of 2000 … elaborate the relevant Irish Building Legislation concerning building access, i.e. Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Building Regulations …

Access and Use

M1     Adequate provision shall be made to enable people with disabilities to safely and independently access and use a building.

Sanitary Conveniences

M2     If sanitary conveniences are provided in a building, adequate provision shall be made for people with disabilities.

Audience or Spectator Facilities

M3     If a building contains fixed seating for audience or spectators, adequate provision shall be made for people with disabilities.

Definition for This Part

M4     In this Part, ‘people with disabilities’ means people who have an impairment of hearing or sight or an impairment which limits their ability to walk, or which restricts them to a wheelchair.

Application of This Part

M5     Part M does not apply to works in connection with extensions to and the material alterations of existing dwellings, provided that such works do not create a new dwelling.”

My Note 1:  In order to safely and independently use a building … it is also necessary, under normal conditions, to use the egress routes of a building.

My Note 2:  The limited definition of ‘people with disabilities’ in Requirement M4 does not include, for example, a person without arms … or those people with a mental, cognitive or psychological impairment.

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Technical Guidance Document M (2000, re-printed in 2005) provides guidance in relation to Part M: ‘Access for People with Disabilities’ of the Second Schedule to the Irish Building Regulations.  TGD M was issued by the Department of the Environment, under Article 7 of the 1997 Building Regulations … Statutory Instrument No. 497 of 1997 … which states …

” 7.     (1)  The Minister may publish, or arrange to have published on his behalf, documents to be known as ‘technical guidance documents’ for the purpose of providing guidance with respect to compliance with the requirements of any of the provisions of the Second Schedule.

          (2)  Subject to the provisions of sub-article (3), where works or a building to which these Regulations apply is or are designed and constructed in accordance with any guidance contained in a technical guidance document, this shall, prima facie, indicate compliance with the relevant requirements of these Regulations.

          (3)  The provisions of any guidance contained in a technical guidance document published under sub-article (1) concerning the use of a particular material, method of construction or specification, shall not be construed as prohibiting compliance with a requirement of these Regulations by the use of any other suitable material, method of construction or specification.”

My Note 3:  Since the introduction of national legal building legislation in the early 1990’s, the Irish Building Regulations have a Functional Format, as required by European Union (EU) Law.  In other words, satisfactory compliance with short functional statements is mandated by law … and provided the requirements of those short statements are properly shown to be complied with, it is entirely optional as to which materials, methods of construction, standards and other specifications (including technical specifications) are used.  In this way, the free movement of products and services within the EU is facilitated and encouraged while, at the same time, technical barriers to trade are avoided.

My Note 4:  For the convenience of readers, the short functional statements mandated by law are reproduced, in a shaded box, at the beginning of each of the Technical Guidance Documents.  The Guidance Texts in each Technical Guidance Document, however, are not Prescriptive Regulations.  These texts are merely an indicator of what is likely to be suitable for the purposes of compliance with the Regulations … they are, prima facie (i.e. on ‘first appearance’ only), an indication of compliance ;  they are not ‘deemed-to-satisfy’ the Requirements of Part M.

My Note 5:  Where gaps are identified in the guidance texts of Technical Guidance Document M … and in the absence of an Irish National Standard on Building Access or Accessibility … a suggested hierarchy of approach should be to source an appropriate European Standard (EN) or, if such a standard does not yet exist, then an appropriate International Standard (ISO), or then a National Standard of any country which is a contracting party to the Agreement on the European Economic Area (EEA) which provides in use an appropriate level of Access/Accessibility Performance (refer to Part D of the Second Schedule to the Building Regulations).  In the unlikely absence of any of the above, an appropriate Design Guidance Document – national or otherwise – should be referenced which provides in use an appropriate level of Access/Accessibility Performance.

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Our Organization – Sustainable Design International – provides an independent (and confidential) Accessibility Monitoring and Verification Service.

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Recent Terenure Terraced Housing Fires – Party Wall Failures !!

2011-04-06:  Further to my earlier Post, dated 11 November 2010 … specifically, the photographs in that Post which showed that there was NO Fire and Smoke Separation between a house and its neighbouring property … and my statement that those photographs “could have been taken in almost any house, anywhere in the country” … so widespread is this problem …

On Friday afternoon last, 1 April 2011 … fire spread through a long terrace of houses in the Dublin City Suburbs of Terenure.  Luckily, no one was killed … but it was reported that some people were injured, including a firefighter.  This was very far from being an April Fool’s Day Joke for the owners and occupants of the buildings.  The fire losses for everyone concerned, both direct and indirect, were enormous … and will continue to increase for quite some time.

The unsustainable losses to society, waste of valuable resources and environmental damage … will never be quantified and will remain unknown …

Colour photograph showing the cordoned-off scene in the aftermath of the fires at a Terrace of Housing in Terenure, Dublin City. In the foreground, Gardaí are keeping a watchful eye. Photograph taken by CJ Walsh. 2011-04-04. Click to enlarge.

Colour photograph showing the cordoned-off scene in the aftermath of the fires at a Terrace of Housing in Terenure, Dublin City. In the foreground, Gardaí are keeping a watchful eye. Photograph taken by CJ Walsh. 2011-04-04. Click to enlarge.

I will make no comment here about the fires, how they started, or any of the people involved on the day of the fire. 

Colour photograph showing the Detail of a Party Wall ... the wall separating one property from another ... in the aftermath of the fires at a Terrace of Housing in Terenure, Dublin. Photograph taken by CJ Walsh. 2011-04-04. Click to enlarge.

Colour photograph showing the Detail of a Party Wall ... the wall separating one property from another ... in the aftermath of the fires at a Terrace of Housing in Terenure, Dublin. Photograph taken by CJ Walsh. 2011-04-04. Click to enlarge.

What I can say, with clarity and precision, is that the Party Walls between the different properties utterly failed to perform, i.e. to provide adequate Fire Separation between those properties … in other words, to resist the passage of heat, smoke and flame from one side of the Party Wall to the other … both during the fire, and for a minimum period afterwards … during the ‘cooling phase’.

I was shocked at how these fires spread through the long terrace … but I was not surprised !

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Why has this serious problem with our housing stock been allowed to fester for so long ???

Most of the Answer lies not in the Relevant Functional Requirements of Part B of the Irish Building Regulations … but in this Diagram 13 below, which is contained in Technical Guidance Document B (2006): ‘Fire Safety’.  The details shown are technically incompetent, and will NOT work in a ‘real’ fire incident.  The reference to Paragraph 3.2.5.10 at the top right hand corner of the diagram is an error … the reference should be to Paragraph 3.2.5.11: ‘Junction of Compartment Wall and Roof’.

Black and white graphic image showing part of Diagram 13: 'Junction of Compartment Wall with Roof' ... in Irish Building Regulations Technical Guidance Document B: 'Fire Safety'. These details are technically incompetent. Click to enlarge.

Black and white graphic image showing part of Diagram 13: 'Junction of Compartment Wall with Roof' ... in Irish Building Regulations Technical Guidance Document B: 'Fire Safety'. These details are technically incompetent. Click to enlarge.

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Status of the Guidance Text in Ireland’s TGD B: ‘Fire Safety’

‘ The materials, methods of construction, standards and other specifications (including technical specifications) which are referred to in this document are those which are likely to be suitable for the purposes of the Regulations.  Where works are carried out in accordance with the guidance in this document, this will, prima facie, indicate compliance with Part B of the Second Schedule of the Building Regulations.  However, the adoption of an approach other than that outlined in the guidance is not precluded provided that the relevant requirements of the Regulations are complied with.’   [Page 2 of Technical Guidance Document B]

It is of critical importance to know and understand that Guidance Text in the Irish Technical Guidance Documents is NOT prescriptive regulation, and it is NOT ‘deemed-to-satisfy’.  All of the Technical Guidance Documents contain errors … they are not infallible documents … and, with sufficient time, technical guidance becomes outdated and inadequate.  This is routine, and to be expected.

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Similar Details to those in Diagram 13 above, which are shown in the various editions of the HomeBond House Building Manual, are equally incompetent.  Furthermore, before the First Edition of the Manual was ever published in the early 1990’s … I stated this fact, very directly, to the individual having responsibility for leading the Manual Project.

And furthermore … Similar Details, which are contained in Diagram 11 of the British (England & Wales) Building Regulations Approved Document B (2006): ‘Fire Safety’ … Volume 1 – Dwellinghouses, are just as incompetent as the Irish details.  This is compellingly relevant, at the present time, since word on the jungle drums is very strongly indicating that our Department of the Environment, Heritage & Local Government (DEHLG) is seriously considering a major updating of Ireland’s Technical Guidance Document B.  And just give one guess where they will go for the model template ??!!??   Ah, go on … go on … go on … go on … guess !!!

The Rest of the Answer can be put down to the Poor Technical Skills of DesignersBad Workmanship on Site, building with Materials and Products which are not ‘Fit for their Intended Use’ … and an Inadequate National System of Local Authority and/or Independent Technical Control.

Check out the Party Walls in your Attic Roof Spaces today !!

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Landfill Fires & Contaminated Water Supplies – Join Some Dots ?

2011-02-23:  With the blanket media coverage of the upcoming Irish General Election, which will be held on Friday next, 25 February 2011 … the following 2 Environmental Protection Agency (EPA) Press Releases concerning the ongoing Kerdiffstown Landfill Fire Incident in County Kildare … which were issued in quick succession on Friday afternoon last, 18 February 2011 … may not have received adequate public attention …

1.  Friday 18th February 2011: Statement on Behalf of Co-Ordinating Group

Re:  Kerdiffstown Fire

Date released: Feb 18 2011, 3:12 PM

Active firefighting has been wound down as brigades undertake a phased withdrawal from the Kerdiffstown landfill site near Naas.  The fire, which flared up on 18 January 2011, was unprecedented in Ireland and it proved very challenging.  Initial assessments indicate that, by comparison with international experience, the time taken to suppress the fire was relatively short – given its nature and the environment in which it took place.  Fire brigades will maintain a precautionary watch on the site until the middle of next week.  The site remains a very dangerous area and people should not enter it for any reason.  The Environmental Protection Agency has increased security in the interests of public safety and to prevent further trespass in the area.

And …

2.  EPA to Develop Remediation Plan for Kerdiffstown Landfill, Naas, County Kildare.

Date released: Feb 18 2011, 3:26 PM

The EPA, HSE, Kildare County Council, Defence Forces and Gardaí have, for the past 27 days, been co-ordinating actions to deal with the fire and other environmental issues at Kerdiffstown Landfill, near Naas.  In particular, the EPA has been working closely with Kildare Fire Service, providing expert advice in fighting the serious fire at the Kerdiffstown landfill site, contracting in providers of cold gas injection equipment and providing air monitoring and analysis.  The EPA is exercising its powers under Section 56 of the Waste Management Act to secure the site and to start the longer-term process of remediation of the whole site.  Already the EPA has begun the following preliminary works:

  • removing stockpiles of fire-risk waste ;
  • providing 24-hour security personnel at the site for the long-term ;
  • establishing an on-site office ;
  • increased on-site monitoring and inspection ;
  • dealing with immediate Health & Safety issues on the site ;
  • removing landfill leachate.

As the plan for the remediation progresses, the EPA will be meeting with the local community on a regular basis in order to hear their views and update them on the remediation project.  Remediation works will be phased and the EPA will prioritise work that alleviates odour from the site in the short to medium term.  Funding for the short-term emergency works to date has been provided by the Department of Environment, Heritage & Local Government.  Further funding for the remediation will be released on a phased basis.  The EPA has taken enforcement action against those involved in the operation of the Kerdiffstown site, including three High Court cases.  High Court orders are in place preventing the deposit of any further waste onto the Kerdiffstown site.  The EPA will use its powers under the Waste Management Acts to seek recovery of all costs expended by the State during the remediation project.  The EPA is also seeking orders against directors of the companies who formerly operated the site in order to recover these costs.  A criminal investigation file relating to the previous operations at the site has been submitted to the Director of Public Prosecutions.

A lot of words have been used in these press releases … but the amount of actual information which has been communicated to the public is Sweet FA !   And … please note well … there is no statement that the Landfill Fire has been extinguished.

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PROTECTION OF FIREFIGHTERS & KERDIFFSTOWN LOCAL COMMUNITY

We consider that it is very important for Firefighters and Members of the Kerdiffstown Local Community, i.e. anybody who lives within 2 Km of the Landfill Site, to have sufficient information about Landfill Fires … in order to ask some pertinent questions about this fire incident.

I hate to say this … but, languishing on an important page of the FireOx International WebSite for many years … http://www.sustainable-design.ie/fire/proenv.htm … unloved (?!?) … has been this 2002 United States Report

U.S. Fire Administration – Federal Emergency Management Agency

May 2002 / FA-225

LANDFILL FIRES – Their Magnitude, Characteristics, and Mitigation

Click the Link Above to read and/or download PDF File (583 kb)

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As you read the document … pinch yourself hard, and try to remember that the Regulatory Control over Landfill Sites in Ireland has been LITE-LITE-LITE !!!   … That there has been much illegal dumping all over the country !!   … AND … That some Local Authorities have even forgotten where old, inactive Landfill Sites are located … a case I myself encountered in Clontarf, within the functional area of what was then known as Dublin Corporation !

Black and white drawing ... Figure 1 in the 2002 U.S. FEMA Landfill Fires Report above ... showing the components of a Regulated Landfill Site, courtesy of the California Waste Management Board. How many Landfill Sites in Ireland, or in Europe for that matter, have all ... or any ... of the components illustrated above ? Click to enlarge.

Black and white drawing ... Figure 1 in the 2002 U.S. FEMA Landfill Fires Report above ... showing the components of a Regulated Landfill Site, courtesy of the California Waste Management Board. How many Landfill Sites in Ireland, or in Europe for that matter, have all ... or any ... of the components illustrated above ? Click to enlarge.

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LANDFILL EMISSIONS – CLIMATE CHANGE & FIRE SAFETY ISSUES !

Extract from the 2002 U.S. Report … Page 8 …

Landfill emissions are the result of the decomposition of organic materials in the landfill (including yard waste, household waste, food waste, and paper).  Because of the nature of the construction of landfills, this decomposition is anaerobic and results in the production of large quantities of Methane (which is highly flammable) and Carbon Dioxide.  In fact, landfills are the largest source of methane emissions in the United States, accounting for 35% of methane emissions in 1999.  MSW (municipal solid waste) landfills generate about 93% of U.S. landfill emissions; industrial landfills account for the remaining emissions.  Methane emissions from landfills are affected by site-specific factors such as waste composition, available moisture, and landfill size.  Approximately 28% of the methane generated in landfills in 1999 was recovered.  The remainder of landfill-generated methane was dispersed in the air.

Approximately 50% of gas emitted from landfills is methane; carbon dioxide accounts for about 45 percent, and the remainder is composed of nitrogen, oxygen, hydrogen, and other gases.  Both Methane and Carbon Dioxide are Greenhouse Gases (GHG’s) that pose environmental problems.  Of the two gases, methane is far more potent than carbon dioxide.

[Media reports have also stated that Carbon Dioxide was used during attempts to suppress the Kerdiffstown Landfill Fire in County Kildare !?!]

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HEALTH EFFECTS OF LANDFILL FIRES !

Extract from the 2002 U.S. Report … Pages 14 & 15 …

In addition to the burn and explosion hazards posed by landfill fires, smoke and other by-products of landfill fires also present a health risk to firefighters and others exposed to them.  Smoke from landfill fires generally contains Particulate Matter (the products of incomplete combustion of the fuel source), which can aggravate pre-existing pulmonary conditions or cause respiratory distress.  As with all fires, those in landfills produce toxic smoke and gases.  The danger and level of toxicity of these gases depend on the length of exposure one has to them and on the type of material that is burning.

Underground fires can result in CO (Carbon Monoxide) levels in excess of 50,000 ppm (parts per million) – the Occupational Safety & Health Administration (OSHA) permissible exposure limit for CO is 50 ppm.  OSHA standards prohibit worker exposure to more than 50 parts of the gas per million parts of air averaged during an 8-hour time period.  Carbon Monoxide is harmful when breathed because it displaces oxygen in the blood and deprives the heart, brain, and other vital organs of oxygen, which can cause permanent damage or death.

Another serious concern in landfill fires is the emission of Dioxins.  Accidental fires at landfills and the uncontrolled burning of residential waste are considered the largest sources of dioxin emissions in the United States.  The term ‘dioxins’ refers to a group of chemical compounds with similar chemical and biological characteristics that are released into the air during the combustion process.  Dioxins are also naturally occurring and are present throughout the environment.  However, exposure to high levels of dioxins has been linked to cancer, liver damage, skin rashes, and reproductive and developmental disorders.

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ENVIRONMENTAL IMPACT OF LANDFILL FIRES !

Extract from the 2002 U.S. Report … Pages 16 & 17 …

The smoke and run-off from landfill fires can be dangerous to those living in the area and to the environment.  It is important that air and water quality issues be addressed early in a fire suppression operation to prevent contamination as much as possible.  As mentioned earlier, water used to suppress a landfill fire can overwhelm a facility’s leachate collection system, if one exists (older facilities may have been constructed prior to regulations requiring leachate collection systems).

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FIRE & LANDFILL CONTENTS !

Extract from the 2002 U.S. Report … Page 17 …

Fires occurring in landfills where hazardous wastes are buried can be particularly difficult.  In past years, illegal dumping of hazardous and toxic materials in landfills and other dumping sites was relatively common.  When a fire occurs and rescue workers have wrong or misleading information about the buried contents (e.g., illegal or unknown toxic or radioactive wastes), the fire suppression operation can be extremely dangerous.

Although not a landfill fire, the Wade Dump Fire in February 1978 clearly illustrates the dangers posed by fires involving unknown hazardous materials.  Firefighters responded to a suspected tyre fire at an abandoned rubber shredding plant on the Delaware River outside of Philadelphia.  They were unaware that the property’s owner and namesake, Melvin Wade, had transformed the plant into one of the most toxic hazardous waste dumpsites in U.S. history.  By the night of the fire, more than 3 million gallons of cyanide, benzene, toluene, and other chemicals were stored on the site – plus thousands of junk tyres.  The burning chemicals produced multi-coloured smoke and noxious fumes, which alerted firefighters to the unusual nature of the fire they were fighting.  Intensified by chemicals and other fuels, the fire raged for hours.  Drums of chemicals exploded, injuring firefighters and even damaging fire trucks.  As the night progressed, firefighters and other emergency workers noticed that the chemicals were dissolving their protective gear and making it difficult for them to breathe; more than 40 firefighters were sent to a nearby hospital for treatment.  Over the past 20 or more years, dozens of those who were present at the Wade Dump fire have become ill, and many have died from cancers and other diseases.  Melvin Wade and others responsible for creating the toxic site were found criminally responsible for their actions.

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JOINING SOME DOTS – CONTAMINATED PUBLIC WATER SUPPLIES IN IRELAND

On Thursday, 17 February 2011 … the Environmental Protection Agency (EPA) released the following report … with an accompanying, ‘spinned’ press release …

Environmental Protection Agency – Ireland

2011-02-17

The Provision & Quality of Drinking Water in Ireland – A Report for the Years 2008-2009

Click the Link Above to read and/or download PDF File (2.77 Mb)

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Once again … pinch yourself hard, and try to remember that the Regulatory Control over Public Water Supplies in Ireland has been LITE-LITE-LITE !!!   Our Public Water Supplies are not in good shape … to say the least.  However, the management and control of the country’s landfill sites – legal, illegal and no longer known – IS a relevant and related issue to the contamination of our public water supplies … not the only issue.

Now, I don’t know about you … but I certainly am not happy about either the accuracy, or the reliability, of the recent EPA Report on Ireland’s Public Water Supplies !

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Ireland’s Proposed Climate Change Legislation – Shambolic !!

2011-01-30:  ANYWAY … continuing on from yesterday …

In December (2010) … Mr. John Gormley T.D., Irish Minister for the Environment, Heritage & Local Government published the 2010 Climate Change Response Bill.  This proposed legislation is intended to set out a range of measures to statutorily underpin Ireland’s transition to a sustainable, climate change resilient and low carbon-based fuel consuming society … not forgetting, always (!), that there are other Greenhouse Gases (GHG’s) specified in the UNFCCC’s 1997 Kyoto Protocol besides Carbon Dioxide (CO2) … which most people do forget.

The Minister had then invited interested parties to submit their views on the Bill – available to download from the Department of the Environment, Heritage & Local Government (DEHLG) WebSite at  http://www.environ.ie/  … by Friday, 28 January 2011.  Three other documents which were relevant to this ‘consultation’ are:  an Explanatory and Financial Memorandum on the proposed legislation, the Bill’s Regulatory Impact Assessment and the Minister’s 2011 Carbon Budget Dáil Statement.

In his 2011 Carbon Budget Speech to the Dáil (Irish Parliament), the Minister had proclaimed the following …

” In providing a legislative underpinning for proactive transition, it (the 2010 Bill) presents the Irish people as an informed and progressive society pursuing a smart economy in the truest sense of the term – an economy that is highly productive, competitive, resource-efficient and environmentally sustainable.”   and

The Bill is both innovative and inspirational, and I look forward to a frank and honest public debate when it is published.”

WOW !!!   Hold De Horses !!!!

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Two important national lobby groups have recently thrown some spanners into the works … the Irish Farmers’ Association (IFA) raised some positive and interesting issues which should be brought to the attention of DG CLIMA in the European Commission … see this Page on the IFA WebSite … http://www.ifa.ie/CrossSectors/ClimateChangeandRenewables.aspx … while the Irish Business & Employers Confederation (IBEC) have been predictably negative and a right pain in the ass … see this Page on their WebSite … http://www.ibec.ie/IBEC/Press/PressPublicationsDocLib3.nsf/vPages/2BEBCAA836D7D6E08025781D00428C39?OpenDocument

The well-publicized positions adopted by these lobby groups prove the point, however, that far more than slick marketing campaigns are required to raise popular awareness about climate change … to properly mobilize society for climate change action, i.e. adaptation as well as mitigation … and reliable implementation.

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MEANWHILE …

As far as Irish Senior Civil Servants are concerned … the temporary, blow-in politicians (also referred to, by them, as ‘defecating birds of passage’) … in this particular case, Mr. John Gormley … have merely departed the scene … this time, a little earlier than expected.  But, the permanent system of national dysfunctional governance, i.e. the Civil Service, continues to ride on into the golden sunset … serving their own interests, and not always the country’s !

Whatever is happening at a political level … you should still have regarded Friday, 28 January 2011 … as the latest date for receipt of written responses on Ireland’s Proposed Climate Change Response Bill.   If slightly late, get those responses in anyway … as early as possible after the weekend !

The Civil Servants in the Department of the Environment, Heritage & Local Government (DEHLG) need all the help that they can get !!

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IRELAND’S NEARLY-ACTUAL CLIMATE CHANGE PERFORMANCE

On 14 December 2010, the Economic & Social Research Institute (ESRI) published a report: ‘The Energy & Environment Review 2010’ … available for download at  http://www.esri.ie/ … which contained a certain Figure 6.  Please bear in mind that there are large uncertainties associated with all of the data contained in the document (see more below) … a point acknowledged by the ESRI …

Colour image showing Figure 6: 'Greenhouse Gas Emissions by Gas According to the Low Growth Scenario' ... from the Economic and Social Research Institute (ESRI) Report: 'The Energy & Environment Review 2010', published in December. Click to enlarge.

Colour image showing Figure 6: 'Greenhouse Gas Emissions by Gas According to the Low Growth Scenario' ... from the Economic and Social Research Institute (ESRI) Report: 'The Energy & Environment Review 2010', published in December. Click to enlarge.

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Ireland’s Climate Change Action to date, i.e. effective Climate Change Mitigation and Adaptation Implementation, has been laboriously slow and lethargic.  It may best be characterized as ‘Business as Usual’, combined with some ‘Cosmetic Tinkering at the Edges’ as the need arises … the universal excuse, almost a mantra, being that “the competitiveness of the national economy must not be impaired”.  National Performance has been guided by an official policy of exploiting to the maximum all of the UNFCCC Kyoto Protocol’s Flexibility Mechanisms while, at the same time, showing a stark indifference to Climate Change Adaptation … an over-reliance on Marketing Campaigns in the public media as opposed to mandatory implementation on the ground … and a preference for ‘Soft’ Performance Estimation on paper/computer monitor screen rather than the more painful ‘real’ performance calculation, which would generate reliable data and statistics to be managed by Ireland’s Central Statistics Office (CSO), in co-ordination with EuroStat in Luxembourg.

Figure 6 from the 2010 ESRI Report … indicates that Official Ireland only ever had a short-term strategy, which was to meet the Kyoto Protocol’s 2012 GHG Emission Reductions Target … on paper !   Right now, it looks like we may only just manage to meet that Target because of the current serious economic recession.  This performance improvement … temporary only … masks fundamental problems within Irish Society.  After 2012, all bets are off … as we won’t be in a position to meet any reasonably foreseeable EU or International GHG Emission Reduction Targets.  If economic growth takes off again, in Ireland, during the second half of this decade … not a completely mad notion … we will be in real trouble !

The Department of Environment, Heritage & Local Government (DEHLG) lacks strong and competent political direction and the institutional capacity to effectively co-ordinate, oversee and implement National Climate Change Action.  For this reason, closer scrutiny of the Department’s activities, from the Dáil Committee System, will be an absolute necessity.

Ireland’s proposed climate change enabling legislation … the 2010 Climate Change Response Bill … is the belated manifestation of a shambolic and pathetically inept effort on the part of Mr. John Gormley, T.D. … and the Senior Civil Servants in the Department of the Environment, Heritage & Local Government (DEHLG) !

Why, So, Because … ?

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SOME SPECIFIC COMMENTS ON THE 2010 CLIMATE CHANGE RESPONSE BILL

     1.  In the light of elaborate claims made about this proposed legislation and also, for example, the separate project to establish an International ‘Green IFSC’ in Dublin … the 2010 Climate Change Response Bill will be closely examined outside Ireland … particularly by the most advanced ‘developing’ economies and the ‘least developed’ economies of the world.

However, a keen awareness about the highly divisive and difficult political issues at the heart of current international climate change negotiations would have dictated that the following be discussed in a Preamble or Introductory Section to the Bill:

  • An acknowledgement of Ireland’s Historical Responsibility for contributing to global climate change ;
  • A national commitment to fully support the move towards an Internationally Agreed Cap of 1.5 degrees Celsius on the planetary temperature rise ;
  • A national commitment that Ireland will meet its International & European Union Climate Change Obligations through the efforts of Irish Society alone.  In other words, we will not seek to benefit, unfairly, from any of our Foreign Development Aid to countries in Africa and Asia … or to projects in Africa, Asia, the Western Balkans, Eastern Europe, Palestine or the Caribbean.

[All such Foreign Development Aid from Ireland should be immediately ‘climate change’ proofed.]

     2.  It is only economists who mistakenly believe that everything in society is merely an ‘input’ to economic ‘output’.  Mercifully, the rest of us know otherwise.  A Society is much, much more than its Economy !

It is a fundamental value and principle that All Aspects of Sustainable Human & Social Development must be taken into account at the same time and with the same weight.  A blinkered approach which only considers the environmental aspects of this overarching concept is damaging, and seriously counter-productive in the longer-term.

The case study of the Proposed Shannon River – Dublin City Region Water Supply Project … discussed in a previous post … very clearly shows that there is a symbiotic Relationship between the Concept of Sustainable Human & Social Development and the Reality of Climate Change … a robust link which is critical to the development of an elusive Global Consensual Response to the threat … and essential for the effective implementation of any Climate Change Strategy in Ireland.

The Existing Lines 11-15 in the 2010 Bill are conceptually flawed … and drafted carelessly and imprecisely.  Revise these lines accordingly …

TO MAKE PROVISION FOR THE SETTING, AND ACHIEVEMENT, OF NATIONAL GREENHOUSE GAS EMISSION REDUCTION TARGETS TO FURTHER TRANSITION TO A SUSTAINABLE, CLIMATE CHANGE RESILIENT AND LOW CARBON-BASED FUEL CONSUMING SOCIETY ;

For Consistency … Revise Section 5 (3) (a) – Section 5 (6) (a) – Section 6 (1) (a) – Section 9 (1) – the final portion of Section 10 (2) – and Section 11 (1) (c) of the Bill.

     3.  No satisfactory explanation has ever been given, in Ireland, for not choosing a Common Baseline Year of 1990 for all of the Kyoto Greenhouse Gases.  Revise Section 2 (2) of the Bill as follows …

For the purposes of this Act –

(a)  the baseline year applicable to a class A greenhouse gas shall be 1990;  and

(b)  the baseline year applicable to a class B greenhouse gas shall be 1990.

In Section 4 (1) – Section 4 (2) – and Section 4 (3) of the Bill … Revise all GHG Emission Reduction Targets and express them, clearly and simply,  in terms of the single Common Baseline Year of 1990.

Thankfully … Ireland’s GHG Emission Reduction Targets will be dictated to us as a result of Agreements at International and/or European Union levels.  Any aspirations with regard to Ireland taking a lead role in climate change action, at any level, are pure fantasy !

     4.  National GHG Emissions – Towards Reliable Data and Statistics

At present … the National ‘GHG Emission’ Database is managed by the Environmental Protection Agency (EPA).  The EPA is not a statistical organization, and necessary statements of uncertainty are not presented with emissions data.  The National ‘GHG Emission’ Database is unreliable.

A major part of the EPA’s National ‘GHG Emission’ Database is dependent upon National Energy Consumption and Efficiency Performance Data.  The National ‘Energy’ Database is managed by Energy Ireland (SEAI).  Energy Ireland is also not a statistical organization, and necessary statements of uncertainty are not presented with energy data.  The National ‘Energy’ Database is unreliable.

For a number of years, however, Energy Ireland has been in possession of reliable information which shows that there is a dramatic difference between the claimed ‘theoretical’ energy conservation and efficiency performance of buildings at design stage … and the actual energy performance of ‘real’ buildings … such is the poor quality of construction on Irish Building Sites.  It is therefore possible to state, with confidence, that the National ‘Energy’ Database managed by SEAI is corrupt !

[See previous posts … Energy Ireland has consistently refused to release the full details of this information into the public domain.  I know, because I am tired asking !]

To be reliable … National ‘GHG Emission’ and ‘Energy’ Databases must be managed directly by the Irish Central Statistics Office (CSO), in co-ordination with EuroStat in Luxembourg … and necessary statements of uncertainty must always be presented with data.

A revised Climate Change Response Bill must confront this serious issue now … and deal with it properly.

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Climate Change ?#$#? … 2007 SDI Letter to John Gormley !

2011-01-29:  Some people say that a week is a long time in politics … but, here in Ireland, during the last two weeks … every single day feels like a year !   To the uninformed outside observer, this may have all the appearance of being an elaborate circus … but, we like our politics to be complex, interesting and very frothy.

Briefly … the Irish Green Party has recently removed itself, awkwardly, from the Ruling Coalition Government in this country … and the Green Party Agenda has gone up in smoke … definitely a Climate Changing Greenhouse Gas !   Mr. John Gormley T.D., Leader of the Green Party, has therefore resigned as Minister for the Environment, Heritage & Local Government … and his Green Party departmental colleague, Mr. Ciarán Cuffe T.D., Minister of State with special responsibility for Sustainable Transport, Horticulture, Planning and Heritage at the Departments of the Environment, Transport and Agriculture has also resigned.

With all of Ireland’s current economic woes … this decision by the Green Party has ensured that ‘Climate Change’ is fast dropping off the list of national priorities.

However, as a result of these political shenanigans … the word ‘Green’ has received a severe hammering and will induce a nasty taste in the mouths of many Irish Voters during the next few weeks which lead up to a General Election.  To be honest, I heartily cheer this development … since ‘GREEN’-ness, i.e. a sole and blinkered consideration for the Environmental Aspects of Sustainability is a ‘pre-version’ (fans of the film: ‘Dr. Strangelove’ will understand what I mean) of Sustainable Human & Social Development.  It is also a peculiar quirk of ‘greens’ that they love the environment … but hate people !

As a prelude to what I will say about the proposed enabling legislation for climate change action in Ireland … the 2010 Climate Change Response Bill … I thought that it would be interesting to reveal the contents of a submission I made to Mr. John Gormley back in late 2007.  Concerning his reaction … I wondered how it was possible for anybody to write such a long letter in reply, and say nothing.

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Mr. John Gormley T.D.,                                                                                           2007-12-18.

Minister for the Environment, Heritage & Local Government,

Department of the Environment, Heritage & Local Government (DEHLG),

Custom House – Dublin 1.

Re:  Your Meeting with IIEA on Friday, 7th December 2007

Dear Minister,

At the Meeting with the Institute of International & European Affairs (IIEA), in North Great George’s Street, I raised two points directly with you:

     i)   The Great Difference between ‘Real’ Building Energy Performance and Claimed ‘Theoretical’ Performance.   In a context where the mandatory use of long wave infra-red thermal imagery will not be introduced in the Revised Technical Guidance Document L of the Building Regulations, due to be issued shortly, and there will continue to be No Effective System of Building Control anywhere in the country … no relationship exists between Claimed ‘Theoretical’ Performance and ‘Real’ Performance, such is the poor quality of construction on Irish Building Sites.  The Energy Numbers which continue to be produced by Sustainable Energy Ireland are – almost – pure fantasy.

     ii)  Sourcing of Climate Change Research & Models for Necessary Institutional Reform Must Extend Beyond Britain.   The following is taken from the Irish National Climate Change Strategy 2007-2012 (page 45) …

‘ Ireland has also engaged in an exchange of information on impacts and adaptation activities through the British-Irish Council. This initiative has focused on exchanging data on research projects which have improved the understanding of climate change impacts at a local level.’

I suggested to you that if this were, actually, to be the approach to Research in Ireland … we will be in serious trouble.  Furthermore, far too many people in important organizations (including the IIEA) are only looking across the water for Models of Necessary Institutional Reform.  We must also, in Ireland, look to the rest of Europe and Japan to find the Best Research and the Most Effective Institutional Models.

Please see the enclosed World Business Council for Sustainable Development (WBCSD) Summary Report: ‘Energy Efficiency in Buildings – Business Realities & Opportunities’ (October 2007), which was presented at an important Paris Conference at the beginning of November, 2007.

This Report looks at what can be achieved in Europe and many other parts of the world – today – using currently available building technologies and systems … IF ‘real’ implementation is taken seriously.  Barriers to progress and costs have also been examined.

In the final analysis, however, a properly resourced Indigenous Research Capability, focused on Irish Conditions and Needs, is vitally necessary to drive ‘Real’ Performance and Innovation in this country.

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Post-Bali Leadership from Ireland (and DEHLG !)

A Kyoto II Instrument will be agreed and ratified before the end of 2012.  The 1997 UNFCCC Kyoto Protocol must now be seen, therefore, as just the beginning of a long-term process which will last until the end of the century.  Some Necessary Direction and a large pinch of Ethical Leadership are urgently required to properly re-position Ireland in this Process.

The following Post-Bali Target Scenario for Ireland is presented for your consideration:

  • Ireland should set 1990 as the Benchmark/Base Year for All Kyoto Greenhouse Gases ;
  • Statements of Measurement and Calculation Uncertainty should be fully transparent (nationally, and at EU level), and made at every stage of Ireland’s Kyoto Compliance ;
  • The EU’s Objective of a 30% Reduction in Greenhouse Gases by 2020, compared to 1990, is the Relevant Short Term Target (refer to Paragraph 31 of the German Presidency Conclusions from the E.U. Council’s Brussels Summit on 8th and 9th March 2007) ;
  • As our ‘Real’ Performance, under Kyoto I, continues to be so weak and disingenuous … we should not expect to receive as generous an intra-EU burden sharing arrangement as before.  Instead, Ireland should adopt the 2020 National Target of a similar 30% Reduction in Greenhouse Gases, compared to 1990 ;
  • Our Contingency Target for 2020 should be a 33% Reduction in Greenhouse Gases, compared to 1990.  When considering ‘real’ performance in any field of human endeavour, it is usual to include a safety factor in any calculations …. in this case, 3% ;
  • Ireland’s Recourse to the Use of Carbon Sinks and Kyoto Mechanisms in meeting the 2020 Contingency Target should be restricted to 1/4 of ‘Real’ Performance …
    • ‘Real’ Performance (no sinks/mechanisms) – minimum 24% Reduction in Greenhouse Gases by 2020, compared to 1990 ;
    • Use of Carbon Sinks and Kyoto Mechanisms – 9% Reduction in Greenhouse Gases by 2020, compared to 1990 (this figure includes the contingency 3%) ;   and
    • As the Construction Sector (when properly identified) should share more of the national burden than, for example, Agriculture …. its Target should be a 40% Reduction in Greenhouse Gases by 2020, compared to 1990.  Remember the range of reductions which were initially proposed at Bali …. 25-40% ?
  • Part 1 of SDI’s Submission for the Irish Construction Sector (IIEA Climate Change Project, Sectors Sub-Group – June 2007) stressed the great need to properly restore the Construction Sector’s Infrastructure.  Otherwise, this Sector will not be able, in reality, to reach any Energy Performance Targets … low or high.  Of course, what will eventually appear on paper, or as a computer print-out, is an entirely different matter !

However, having been able to access information about the recent WBCSD Research Project, and using it as a valid substantiation … it then became possible to deal with the issue of Energy Performance Targets for All Buildings (new, existing and those of historical, architectural and cultural importance) more aggressively.

Enclosed, please also find Part 2 of SDI’s Submission for the Construction Sector (IIEA Climate Change Project, Sectors Sub-Group – November 2007).

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Ireland’s Climate Change Strategy ?

     1.  Ireland’s Current ‘Real’ Situation with Regard to Kyoto (I) Compliance should be clearly understood by the Irish Public.  Using the recently issued European Environment Agency (EEA) Report 5/2007: ‘Greenhouse Gas Emission Trends & Projections in Europe 2007 – Tracking Progress Towards Kyoto Targets’, we have extracted just a few snippets of interesting information (enclosed) …

  • Instead of 1990, Ireland has chosen 1995 as the Base Year for HFC’s, PFC’s & SF6 ;
  • Ireland’s Per Capita greenhouse gas emissions are nearly the worst in the EU-27 ;
  • Ireland’s Per GDP greenhouse gas emissions are far too high ;
  • Ireland’s ‘Real’ Distance-To-Target (no sinks/mechanisms) is very bad.

Ireland is still grimly grasping on to a ‘Business as Usual’ Approach.  This is actually being reinforced by the relevant Institutions of the State, who insist on merely Playing with Numbers … and then publishing Cosmetic Public Relations Brochures for consumption in Ireland and, unfortunately, on the wider European and International Stages.

     2.  The following National Policy/Strategy Documents & Legislation should directly relate to one other, and their implementation should be tightly co-ordinated …

  • National Sustainable Development Strategy ;
  • National Climate Change Strategy ;
  • National Climate Change Adaptation Strategy ;
  • National Spatial Strategy ;
  • National Development Plan ;
  • National Public Procurement Law.

Not only have some of the above not yet even been drafted, but others are unacceptably inadequate, outdated and/or fundamentally flawed.  And the synergies which would normally accrue from co-ordinated implementation are being lost.

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

Nothing less than a Complete Cultural Shift will be necessary throughout this Sector, beginning with all research and design disciplines and extending right across to any person who works on a construction site or has any part to play in managing, maintaining or servicing a building.

Yet, Irish Construction is not presented as a Coherent Sector anywhere in National or European Greenhouse Gas Databases.

Separate Strategies are urgently required to greatly improve the energy performance of:

  • Existing Buildings … onto which many energy efficiency measures can be successfully grafted, but they will not be cheap ;
  • Buildings of Historical, Architectural or Cultural Importance … the integrity of which must be protected ;   and
  • New Buildings, which must therefore carry the major burden.

     4.  Raising the (General) Awareness of Irish Society regarding Climate Change and Mobilizing People and Organizations for (Effective) Action are two entirely different concepts.  Which concept is informing Strategy Development within the DEHLG ?

A €15 m. Marketing Campaign, spread over 4-5 Years and including the ‘Change’ WebSite (!?!?), will not mobilize anyone … to do anything.

     5.  Your proposals concerning Necessary Building Energy Efficiency Improvements to be included in the Revised Technical Guidance Document L are inadequate.  Part L should be applicable to ALL New Buildings.

It has also been insufficiently emphasized in public discussions/consultations concerning this issue that any proposed Building Energy Efficiency Improvements must take place in a context of stringent control during construction (by a sufficient number of competent Local Authority Building Controllers and/or Independent Technical Controllers) and rigorous post-construction energy performance monitoring (using long wave infra-red thermal imagery, in conjunction with building external fabric air seepage tests).  Follow-up observation of post-occupation building energy performance will also be required.

This is the one – and only – means of …

  • tweaking Computer Software Tools so as to produce more realistic outputs ;   and
  • obtaining reliable construction-related energy performance data and statistics.

Please Note Well:  Without suitable references to the use of long wave infra-red thermal imagery (essential, if working at ambient temperatures – short wave, if working at high temperatures) in Section 5, the Revised TGD L will be absolutely meaningless !!

Because of wasteful patterns of building management and/or use – even in the most energy efficient building – we would also stress that far more attention should be paid to the concept of Intelligent Energy Efficiency Management.

     6.  We strongly urge you, in accordance with the 2007 Bali Action Plan, to rapidly advance development of the National Climate Change Adaptation Strategy, and to ensure that it is properly implemented.

     7.  We call for the creation of an adequately resourced Sustainable Development Commission with the necessary legal mandate, independence and technical expertise to monitor – in an integrated, continual and proactive manner – Ireland’s mitigation and adaptation performance in relation to the adverse effects of climate change.  We also call for a New Social Partnership for Sustainable Development & Climate Change Adaptation.  Addressing Climate Change must be considered an integral element of Sustainable Development Policies.

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At Sustainable Design International … we continue to find, in everyday practice, that the most challenging barriers to Policy Implementation are Institutional – lack of proper horizontal policy integration in Public Authorities, and antiquated approaches to management in Private Organizations.  At every level, the concept of Sustainable Human & Social Development is poorly understood.

Should you have any questions or comments, please contact me at your convenience.

Yours sincerely,

C.J. Walsh,  etc., etc.

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Carbon Monoxide (CO) Protection in Building Habitable Spaces

2011-01-13:  Carbon Monoxide (CO) is an odourless, colourless and toxic gas.  Because it is impossible to see, taste or smell the toxic fumes, CO can kill you before you are aware it is in your home.  At lower levels of exposure, CO causes mild harmful effects which are often mistaken for the flu (influenza).  These symptoms include headaches, dizziness, disorientation, nausea and fatigue.  The effects of CO Exposure can vary greatly from person to person depending on age, overall health and the concentration and length of exposure.  Source: Environmental Protection Agency (EPA), USA.

Recent tragic deaths from CO Poisoning have occurred in Ireland … not only in the home, but also in a hotel.

Sources of Carbon Monoxide (CO) … unvented kerosene and gas space heaters; leaking chimneys and furnaces; back-drafting from furnaces, gas water heaters, wood stoves, and fireplaces; gas stoves; generators and other gasoline powered equipment; automobile exhaust from attached garages; and tobacco smoke.  Incomplete oxidation during combustion in gas ranges and unvented gas or kerosene heaters may cause high concentrations of CO in indoor air.  Worn or poorly adjusted and maintained combustion devices (e.g., boilers, furnaces) can be significant sources, or if the flue is improperly sized, blocked, disconnected, or is leaking.  Car, truck, or bus exhaust from attached garages, nearby roads, or parking areas can also be a source.  Source: EPA, USA.

 

If there is a fuel burning / heat-producing appliance in any habitable space, in any building … and if you have not done so already … you must do something NOW to check that you are protected effectively from CO Poisoning.  Shift your ass !

In order to improve energy conservation and efficiency in buildings … direct, natural ventilation from the exterior is still being actively discouraged … and buildings are becoming more tightly sealed, during construction or major refurbishment, to prevent unintended air seepage.  Generally, this has been causing a serious increase in Building Related Ill-Health (also known as ‘Sick Building Syndrome’) … much of which is still going un-reported.

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BRIEF CHECKLIST – IMMEDIATE ATTENTION

1.  Check that there is sufficient, clear, direct natural ventilation in any habitable space which contains a fuel burning / heat-producing appliance.  Next … Check that the terminal unit / outlet of the flue coming from that appliance is not blocked.  Then … Check the route of any flue from the appliance.  If, for example, a flue passes through another habitable space … that space must also be properly ventilated.

2.  Check that all fuel burning / heat-producing appliances are ‘fit for their intended use’ (this must be shown !), are working properly … and that they are regularly serviced by people who are competent to do so.  Paperwork is not a reliable indicator of competence !   Remember the problems with FÁS !?!

3.  Do not confuse Carbon Monoxide Detectors with Smoke Detectors !   Only install a dedicated Carbon Monoxide (CO) Detector for the task of detecting Carbon Monoxide.  And … that Detector must be shown to be ‘fit for its intended use’.  Read the writing on the outside of the box carefully … and then read all of the instructions inside the box !

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With regard to the issue of Carbon Monoxide (CO) Poisoning in Ireland … Statistics Gathering is not reliable.  National Legislation concerning the installation of Carbon Monoxide Detectors in buildings should have been introduced many years ago … but this has not yet happened.  Furthermore … don’t hold your breath waiting for this much-needed legislation.  Based on past performance, technical and administrative officials in our relevant authority having jurisdiction, i.e. the Department of Environment, Heritage & Local Government (DEHLG), will prefer to wait before acting until similar legislation is introduced in Britain (England & Wales).

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I will just describe what I have done in my own house … in the kitchen …

[Smoke Detectors are separately linked into a monitored security and fire warning system.]

In every room where a fuel burning / heat-producing appliance is located … a Carbon Monoxide (CO) Detector is installed.  In the kitchen, for example, the Detector is fixed on the wall … at about head height, when sitting down at a table (appropriate for the normal pattern of use there) … and at a distance of approximately 2 metres from the natural gas kitchen range.  Control of direct, natural ventilation to the appliance is active … meaning, it always receives attention.  The usual kitchen clutter, e.g. clothes ‘waiting’ for ironing, etc., is never allowed to cover or block the Detector.  Everybody in the house understands the purpose of this product.

Colour photograph showing a battery-operated Ei Electronics Carbon Monoxide (CO) Detector, Model Ei206D, fixed (tamper proof) to the kitchen wall. Two of the hanging decorative plates are from France and Turkey. As for the third plate ... does anyone remember the Willow Pattern ? Photograph taken by CJ Walsh. 2011-01-12. Click to enlarge.

Colour photograph showing a battery-operated Ei Electronics Carbon Monoxide (CO) Detector, Model Ei206D, fixed (tamper proof) to the kitchen wall. Two of the hanging decorative plates are from France and Turkey. As for the third plate ... does anyone remember the Willow Pattern ? Photograph taken by CJ Walsh. 2011-01-12. Click to enlarge.

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About the performance of the Carbon Monoxide (CO) Detector in the event of a ‘real’ CO Leakage … I am comfortably assured, as I have known the EI Company in Shannon since the mid-1980’s.  At that time, I was the first architect in Ireland to install smoke detectors in any local authority housing scheme … and EI gave great technical back up and support, for which I am still very grateful.  I might add that those same smoke detectors were installed against the wishes of the local fire department.  A report on the whole test installation process was later presented, by Dr. M. Byrne, Engineering Manager of EI, to an International Fire Conference in Dublin.

The particular Carbon Monoxide (CO) Detector shown in the photograph above is a battery-operated Model Ei206D.  There are no heavy, smoke sealed fire-resisting doorsets in the house … so the sound level of the distinct alarm / warning signal [85 dB(A) minimum at 3 metres] is more than adequate.  A few years ago, this was an expensive item to buy !   Now, however, CO Detectors are widely available … and at a more reasonable price.

Very Importantly … Ei Electronics have also developed a range of products – Solutions for All – which are suitable for use by People with Activity Limitationshttp://www.eielectronics.com/ei-electronics/special-needs

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Harmful Health Effects Associated with Carbon Monoxide (CO) Inhalation … at low concentrations: fatigue in healthy people and chest pain in people with heart disease.  At higher concentrations: impaired vision and co-ordination; headaches; dizziness; confusion; nausea.  Can cause flu-like symptoms which clear up after leaving home.  Fatal at very high concentrations.  Acute effects are due to the formation of Carboxyhaemoglobin (COHb) in the blood, which inhibits oxygen intake.  At moderate concentrations: angina, impaired vision, and reduced brain function may result.  At higher concentrations: CO Exposure can be fatal.  Source: EPA, USA.

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Health Service Executive (Ireland) Factsheet

January 2011

Carbon Monoxide (CO) Poisoning – A Guide for GP’s & Other Medical Professionals

Click the Link Above to read and/or download PDF File (375kb)

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DAC’s & An Bord Pleanála (Ireland) – Brief SDI Announcement

The following ‘Warrant of Appointment’ as a Specialist Consultant to the Board … was signed on 17 December 2010 by Mr. John O’Connor, Chairperson of the Board …

An Bord Pleanála

Building Control Acts, 1990 to 2007  |  Building Control Regulations, 1997 to 2009  |  Building Regulations, 1997 to 2008

An Bord Pleanála hereby appoints  C.J. Walsh – Sustainable Design International (SDI)  to:

     (a)  carry out Inspections in relation to appeals against decisions of Building Control Authorities for applications for a Disability Access Certificate (DAC) ;

     (b)  conduct Meetings convened by the Board under Article 34 of the Building Control Regulations, 1997 ;

     (c)  make Written Reports (including Recommendations) to the Board in relation to such appeals ;

and

     (d)  be an Authorized Person, for the purposes of Section 11 of the Building Control Act, 1990.

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The Functions of the Board in Ireland are …

An Bord Pleanála (Irish) … established in 1977, under the Local Government (Planning and Development) Act of 1976 … is responsible for the determination of appeals and certain other matters under the Planning and Development Acts, 2000 to 2010 … and the determination of applications for Strategic Infrastructure Development, including major road and railway projects.  The Board is responsible for dealing with proposals for the compulsory acquisition of land by Local Authorities and other Agencies, under various legal enactments.  The Board also has functions to determine appeals under Water and Air Pollution Acts, and the Building Control Act.

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Disability Access Certificates (DAC’s) – Acceptable Accessibility ?

A few weeks ago … in a post dated 20 October 2010 … Japan in April & May 2010 – Accessibility-for-All ! … I discussed some of the many aspects which, together, facilitate a high level of quality in ‘real’, or actually realized, Built Environment Accessibility Performance in Japan … and I illustrated that quality with a number of photographs.

In time, I will add more photographs from my valuable ‘Accessibility in Japan’ Collection !

Note:  Built Environment … Anywhere there is, or has been, a man-made or wrought (worked) intervention by humans in the natural environment, e.g. cities, towns, villages, rural settlements, roads, bridges, tunnels, transport systems, service utilities, and cultivated lands, lakes, rivers, coasts, seas, etc. … including the Virtual Environment.

Note:  Social Environment … The complex network of real and virtual human interaction – at a communal or larger group level – which operates for reasons of tradition, culture, business, pleasure, information exchange, institutional organization, legal procedure, governance, human betterment, social progress and spiritual enlightenment, etc.

Note:  Virtual Environment … A designed environment, electronically-generated from within the Built Environment, which may have the appearance, form, functionality and impact – to the person perceiving and actually experiencing it – of a real, imagined and/or utopian world.

However … many of these aspects are missing in European Approaches to Accessibility-for-All … and, typically, the level of Accessibility Performance which we are used to experiencing, and accepting, is inadequate, sloppy, poor … and to be direct and honest … BRUTAL !!

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As far back as 2001 … in an Introduction to a Page on our Corporate WebSite illustrating the Inaccessibility of European Union Institutional Buildings … specifically, the European Parliaments in Brussels and Strasbourg … I wrote …

‘ Many times each year, our work takes us to Brussels, Luxembourg and Strasbourg.

In spite of all the rhetoric from European politicians, and the extensive body of European legislation actually in force at national and regional levels in every Member State … the inaccessibility of Institutional Buildings is shockingly and unacceptably bad … in some cases, dangerously so !

Yet, these buildings should represent, in built form, the ideals, values and aspirations of the peoples of Europe – as expressed in the EU Treaties.

What a bitter disappointment ! ‘

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Today … France, in particular, continues to be a depressing experience … where Talk is far, far too cheap … and Good Accessibility Performance is still all too rare !!

Last Thursday, 25 November 2010 … I attended a Paris Meeting of the Editorial Team for the CIB W108 Report: ‘Sustainable Climate Change Adaptation in the Built Environment’.  My airline flights from Dublin brought me in and out through Terminal 1 of Roissy Charles de Gaulle (CDG) Airport in Paris.

A spanking new automatically operated Métro (shuttle) … CDGVAL … connects Terminals 1, 2 & 3, various Multi-Storey Car Parks and Train Stations within the Airport Complex …

Colour image showing the Airport Complex Plan of Roissy Charles De Gaulle in Paris. Note the New CDGVAL Métro ... an important interconnecting transportation system. Click to enlarge.

Colour image showing the Airport Complex Plan of Roissy Charles De Gaulle in Paris. Note the New CDGVAL Métro ... an important interconnecting transportation system. Click to enlarge.

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Colour photograph showing the new, automatically operated CDGVAL Métro at Roissy Charles De Gaulle Airport in Paris. Yet another magnificent example of Sloppy French Accessibility Implementation ! Photograph taken by CJ Walsh. 2010-11-26. Click to enlarge.

Colour photograph showing the new, automatically operated CDGVAL Métro at Roissy Charles De Gaulle Airport in Paris. Yet another magnificent example of Sloppy French Accessibility Implementation ! Photograph taken by CJ Walsh. 2010-11-26. Click to enlarge.

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IF … you search hard enough on the CDG Airport WebSite, you will find these three highlighted short sentences under content with the title Personne à Mobilité Réduite’ … total rubbish and complete bullshit when you actually see the airport’s buildings and many facilities.  And … as usual, in French, the disability-related terminology is evil … and sucks !

‘Aéroports de Paris assure l’assistance des passagers handicapés et à mobilité réduite dés leur arrivée, et tout au long de leur parcours dans le terminal.

Aéroports de Paris a depuis longtemps entamé une démarche d’équipement et d’adaptation de ses terminaux pour faciliter les déplacements de tous.

Aujourd’hui, les problématiques d’accessibilités sont systématiquement prises en compte dans l’aménagement de nos infrastructures.’

Colour photograph showing the Door Threshold Detail of the new, automatically operated CDGVAL Métro at Roissy Charles De Gaulle Airport in Paris. In totally new construction ... an unacceptably huge difference between platform height and the shuttle's floor ! This is also now a trip hazard for everyone !! Photograph taken by CJ Walsh. 2010-11-26. Click to enlarge.

Colour photograph showing the Door Threshold Detail of the new, automatically operated CDGVAL Métro at Roissy Charles De Gaulle Airport in Paris. In totally new construction ... an unacceptably huge difference between platform height and the shuttle's floor ! This is also now a trip hazard for everyone !! Photograph taken by CJ Walsh. 2010-11-26. Click to enlarge.

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Why is this relevant for us now … here in Ireland ?

The new scheme of Disability Access Certification, closely modelled on the existing highly problematic scheme of Fire Safety Certification … is undergoing a normal, introductory ‘teething’ process within this jurisdiction … and many questions about interpretation of the law and its operation are being asked.

Important Clarification:  The Guidance Text contained in Technical Guidance Document M … is not Law … is not Prescriptive Regulation … is not ‘Deemed to Satisfy’ … and … because the guidance is so incomplete, incoherent and inadequate … does not even indicate Minimum Accessibility Performance !

Part M Functional Requirements – Access for People with Disabilities     Second Schedule of the 1997 Building Regulations – As Amended by the Building Regulations (Amendment) Regulations, 2000 – Statutory Instrument No.179 of 2000

Access and Use     M1     Adequate provision shall be made to enable people with disabilities to safely and independently access and use a building.

Sanitary Conveniences     M2     If sanitary conveniences are provided in a building, adequate provision shall be made for people with disabilities.

Audience or Spectator Facilities     M3     If a building contains fixed seating for audience or spectators, adequate provision shall be made for people with disabilities.

Definition for This Part     M4     In this Part, ‘people with disabilities’ means people who have an impairment of hearing or sight or an impairment which limits their ability to walk, or which restricts them to a wheelchair.

Application of This Part     M5     Part M does not apply to works in connection with extensions to and the material alterations of existing dwellings, provided that such works do not create a new dwelling.

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Today in Ireland … Talk IS too cheap … and Good Accessibility Performance IS almost non-existent !!!   Yes … and that even includes the work of those mighty superheroes in the Office of Public Works (OPW).

Furthermore … the big fun will really start when the New Part M Requirements come into operation on 1 January 2012 … and we will enter a surreal Alice’s Wonderland of Accessibility Ambiguity

Part M Functional Requirements – Access and Use     Second Schedule of the 1997 Building Regulations – As Amended by the Building Regulations (Part M Amendment) Regulations, 2010 – Statutory Instrument No.513 of 2010

Access and Use     M1     Adequate provision shall be made for people to access and use a building, its facilities and its environs.

Application of The Part     M2     Adequate provision shall be made for people to approach and access an extension to a building.

M3     If sanitary facilities are provided in a building that is to be extended, adequate sanitary facilities shall be provided for people within the extension.

M4     Part M does not apply to works in connection with extensions to and material alterations of existing dwellings, provided that such works do not create anew dwelling.

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New SDI Report on Climate Change Adaptation – Comments ?

This is the HomePage of my Technical Blog … but on a separate WebPage (see the toolbar above), I have been slowly building content, with links to related sources of information, on the subject of a CIB Working Commission 108 International Climate Change Project, which is about to enter its final important stage.

When published in the spring/early summer of next year … 2011 … the CIB W108 Report: ‘Sustainable Climate Change Adaptation in the Built Environment’ will comprise 2 Parts:

           I  – International Synthesis on Sustainable Climate Change Adaptation.

          II  – National Perspectives on Sustainable Climate Change Adaptation.

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Today, 18 November 2010 … I uploaded onto that separate WebPage the National Report for ‘IRELAND’, which will appear in Part II of the CIB Publication.  I am the person who drafted this report … and it has not been an easy task !   You will see that much attention is paid to institutional and implementation issues.

I now invite comments on the National Report … any comments … from those with a particular interest in the subject … and from the general public.

Comments should arrive here no later than Monday, 20th December 2010 … pretty please !

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Before commenting upon the National Report, however, it would be useful if you also took a glance at the following three relevant documents …

  • Ireland’s 5th National Communication (NC5) under the 1992 United Nations Framework Convention on Climate Change, dated 3 March 2010 ;
  • UNFCCC In-Depth Review of Ireland’s 5th National Communication (NC5), dated 2 November 2010 ;
  • EU WHITE PAPER – Adapting to Climate Change: Towards a European Framework for Action … European Commission Communication COM(2009) 147 final, dated 1 April 2009.

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2009 EU White Paper – ‘Introduction’ (Page 3, first three paragraphs)

Climate change increases land and sea temperatures and alters precipitation quantity and patterns, resulting in the increase of global average sea level, risks of coastal erosion and an expected increase in the severity of weather-related natural disasters.  Changing water levels, temperatures and flow will in turn affect food supply, health, industry, and transport and ecosystem integrity.  Climate change will lead to significant economic and social impacts with some regions and sectors likely to bear greater adverse affects.  Certain sections of society (older people, people with activity limitations, low-income households) are also expected to suffer more.

Addressing climate change requires two types of response.  Firstly, and importantly, we must reduce our greenhouse gas emissions (GHG), i.e. take mitigation action … and secondly, we must take adaptation action to deal with the unavoidable impacts.  The EU’s recently agreed climate change legislation puts in place the concrete measures to reach the EU’s commitment to reduce emissions to 20% below 1990 levels by 2020 and is capable of being amended to deliver a 30% reduction if agreed as part of an international agreement in which other developed countries agree to comparable reductions and appropriate contributions by economically more advanced developing countries based on their responsibilities and capabilities.  However, even if the world succeeds in limiting and then reducing GHG emissions, our planet will take time to recover from the greenhouse gases already in the atmosphere.  Thus, we will be faced with the impact of climate change for at least the next 50 years.  We need therefore to take measures to adapt.

Adaptation is already taking place but in a piecemeal manner.  A more strategic approach is needed to ensure that timely and effective adaptation measures are taken, ensuring coherency across different sectors and levels of governance.

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2009 EU White Paper – The Proposed EU Framework: Objectives & Action (Page 7, #3)

The Objective of the EU’s Adaptation Framework is to improve the EU’s resilience to deal with the impact of climate change.  The framework will respect the principle of subsidiarity and support overarching EU objectives on sustainable development.

The EU’s framework adopts a phased approach.  The intention is that phase 1 (2009-2012) will lay the groundwork for preparing a comprehensive EU Adaptation Strategy to be implemented during phase 2, commencing in 2013.

Phase 1 (2009-2012) will focus on four pillars of action:

1)    building a solid knowledge base on the impact and consequences of climate change for the EU ;

2)    integrating adaptation into EU key policy areas ;

3)    employing a combination of policy instruments (market-based instruments, guidelines, public-private partnerships) to ensure effective delivery of adaptation ;    and

4)    stepping up international co-operation on adaptation.

For phase 1 to be a success … the EU, national, regional and local authorities must co-operate closely.

The proposals set out in this paper cover actions to be taken in the first phase and are without prejudice to the future structure of the EU budget and to the current and future multi-annual financial framework.

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IRELAND – Part II National Report for CIB W108 Climate Change Project

In the spring of 2007, the Department of Environment, Heritage & Local Government (DEHLG) – Ireland’s statutory Authority Having Jurisdiction (AHJ) – published the ‘National Climate Change Strategy 2007-2012’.  This document can be accessed and downloaded at … http://www.environ.ie/en/Environment/Atmosphere/ClimateChange/   It is of concern to note, however, that ‘Climate Change’ related content is not easy to find on this WebSite !   Comprehensive Enabling Climate Change Legislation, which this Department, and the Irish Government, initially promised for Easter 2010 … and then June 2010 … has, at the time of writing (mid-November 2010), still not made an appearance in the Dáil (Ireland’s Parliament) !

The Department of Environment, Heritage & Local Government (DEHLG) lacks strong and competent political direction and the institutional capacity to effectively co-ordinate and oversee the implementation of National Climate Action.  For this reason, closer scrutiny of its activities will be required from the Dáil Committee System.

Contrary to current practice … Foreign Development Aid should not be used to obtain any sort of domestic or in-country credit for Ireland’s National Climate Change Strategy !

Specifically concerning Climate Change Adaptation … the following is stated on Page 45 of the 2007-2012 National Climate Change Strategy Document …

‘As part of a comprehensive policy position on climate change, the Government is committed to developing a national adaptation strategy over the next two years.  This strategy will provide a framework for the integration of adaptation issues into decision-making at national and local level.’

The DEHLG does not, however, intend to publish a National Climate Change Adaptation Strategy until 2013 (Ireland’s NC5).

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Climate Change Action in Ireland – Summary

Ireland’s Climate Action to date, i.e. effective Climate Change Mitigation and Adaptation Implementation, has been laboriously slow and lethargic.  It may best be characterized as ‘Business as Usual’, combined with some ‘Cosmetic Tinkering at the Edges’ as the need arises … the universal excuse, almost a mantra, being that “the competitiveness of the national economy must not be impaired”.  National Performance has been guided by an official policy of exploiting to the maximum all of the UNFCCC Kyoto Protocol’s Flexibility Mechanisms while, at the same time, showing a stark indifference to Climate Adaptation … an over-reliance on Marketing Campaigns in the public media as opposed to mandatory implementation on the ground … and a preference for ‘Soft’ Performance Estimation on paper/computer monitor rather than the more painful ‘real’ performance calculation, which would generate reliable data and statistics to be managed by Ireland’s Central Statistics Office, in co-ordination with EuroStat in Luxembourg.

Despite the importance of the Construction Sector in Ireland and Europe … and its very large adverse impacts on regional and local climate … a significant barrier to concerted Sectoral Climate Action exists because ‘construction’ is not yet identified as a separate Sector, by either the Environmental Protection Agency (Ireland) or the European Environment Agency (Copenhagen) … in National and European Greenhouse Gas (GHG) Emission Databases.  Furthermore, our systems of governance and institutional organization, at both levels, do not appear to have the capacity … either to understand or to manage an effective response to the climate challenges created by the Sector.

Climate Change Mitigation Efforts are failing in Ireland; the current economic downturn merely camouflages that unpalatable fact.  Therefore, the necessary corrective actions described in this National Report fall under the heading of ‘Climate Change Adaptation’.

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