Department of the Environment Heritage and Local Government (DEHLG)

New SDI Report on Climate Change Adaptation – Comments ?

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

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

           I  – International Synthesis on Sustainable Climate Change Adaptation.

          II  – National Perspectives on Sustainable Climate Change Adaptation.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2)    integrating adaptation into EU key policy areas ;

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

4)    stepping up international co-operation on adaptation.

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

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

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

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

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

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

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

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

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

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Climate Change Action in Ireland – Summary

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

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

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

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Hazards in Attic Roof Spaces – A Strong Dose of ‘Reality’ !

It’s all happening here !   From trawling the depths of European Union (EU) Legislation in my last Post … to the heights of Attic Roof Spaces in Ireland … what a magnificent contrast !!

This Post has nothing to do with this law, or that law … or the proper technical control of these sorts of troubling situations.  It has everything to do with a strong dose of Reality’ … and the typical sorts of Serious Hazards which lurk quietly, unannounced and generally unheeded in most houses … houses which are occupied by ordinary, average people.

The following photographs could have been taken in almost any house, anywhere in the country !   These particular photographs, however, were taken during a House Inspection for a good friend, somewhere in County Wicklow, during May 2010 …

Colour photograph showing the typical clutter which can accumulate, over time, in an Attic Roof Space. Wait and see, however, what else is happening underneath and around this clutter. Smoke Detectors should always be fitted in these Spaces as a matter of routine. Also ... notice that this is a trussed timber roof. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
Colour photograph showing the typical clutter which can accumulate, over time, in an Attic Roof Space. Wait and see, however, what else is happening underneath and around this clutter. Smoke Detectors should always be fitted in these Spaces as a matter of routine. Also ... notice that this is a trussed timber roof. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.

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Colour photograph showing fire scorched thermal insulation. Careless Hot Works are a major cause of fires in ALL building types! Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
Colour photograph showing fire scorched thermal insulation. Careless Hot Works are a major cause of fires in ALL building types! Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.

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Colour photograph showing that there is NO fire separation between this house and the neighbouring house at the junction between the party wall and the roof covering. And ... once fire enters this Attic Roof Space, those thin metal connecting plates in the roof trusses will rapidly lose strength, and the entire roof will then collapse. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
Colour photograph showing that there is NO fire separation between this house and the neighbouring house at the junction between the party wall and the roof covering. And ... once fire enters this Attic Roof Space, those thin metal connecting plates in the roof trusses will rapidly lose strength, and the entire roof will then collapse. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.

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Colour photograph showing a very badly constructed party wall ... see the many gaps in the joints between the concrete blocks. Just because a wall is made of masonry ... do not, for a single moment, assume that it is either smoke resisting or sound resisting. Also ... notice the sloppy DIY electrics. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
Colour photograph showing a very badly constructed party wall ... see the many gaps in the joints between the concrete blocks. Just because a wall is made of masonry ... do not, for a single moment, assume that it is either smoke resisting or sound resisting. Also ... notice the sloppy DIY electrics. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.

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Colour photograph showing, after I had pulled back a portion of thermal insulation, where the insulation had completely covered a downlighter. In other parts of this Attic Roof Space chipboard, to hold all of the clutter, covers the transformers as well. Downlighters need direct ventilation to facilitate the escape of heat. Also ... note the trap doorset is not fire and smoke resisting. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
Colour photograph showing, after I had pulled back a portion of thermal insulation, where the insulation had completely covered a downlighter. In other parts of this Attic Roof Space chipboard, to hold all of the clutter, covers the transformers as well. Downlighters need direct ventilation to facilitate the escape of heat. Also ... note the trap doorset is not fire and smoke resisting. Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.

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Colour photograph showing thermal insulation packed tightly into the roof eaves ... choking off essential ventilation pathways. Thermal insulation was also placed under the water storage tanks ... exposing them to freezing external conditions during cold winter nights. Thick, multi-layered thermal insulation will also conceal the bottom horizontal members in all types of timber roof construction ... expect more fall accidents through ceilings in the future! Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.
Colour photograph showing thermal insulation packed tightly into the roof eaves ... choking off essential ventilation pathways. Thermal insulation was also placed under the water storage tanks ... exposing them to freezing external conditions during cold winter nights. Thick, multi-layered thermal insulation will also conceal the bottom horizontal members in all types of timber roof construction ... expect more fall accidents through ceilings in the future! Photograph taken by CJ Walsh. 2010-05-21. Click to enlarge.

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There are simple Design and Construction Solutions to all of these problems … and Competent, Independent Technical Control over the works being carried out is absolutely essential.

BUT … Dysfunctional Government Departments and State Agencies are still … to this day … directly sponsoring and knowingly contributing to these hazardous situations in our homes !

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Dublin IFE Fire Conference – Sustainable Fire Engineering !

2010-10-18:  Nothing less than a complete Paradigm Shift to Sustainable Fire Engineering is now needed … because it is Necessary … because it is Inevitable … because it is The Future !!!

This process will not proceed, however, unless the International Fire Science & Engineering Community begins to communicate and engage, meaningfully, with the Mainstream Construction Sector … where this process is already well advanced.

One Organization in our community has recently decided to bite the bullet … CIB (International Council for Research & Innovation in Building & Construction) … where Working Commission 14 (W14) – ‘Fire Safety’ … agreed, at a meeting in Zurich, to significantly expand and elaborate its own Scope … please note the keywords in bold text …

A CIB Working Commission … W14 is an international, multi-stakeholder, trans-disciplinary, pre-normalization forum for discussion, and action, on research and innovation in Fire Science and Engineering for the design, construction and operation of a Safe and Sustainable Built Environment.

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Colour image showing the Title Page of CJ Walsh's Presentation at the Institution of Fire Engineers (Ireland Branch) Annual Fire Conference ... which will be held on Wednesday, 20th October 2010, in Dublin. Click to enlarge.
Colour image showing the Title Page of CJ Walsh’s Presentation at the Institution of Fire Engineers (Ireland Branch) Annual Fire Conference … which will be held on Wednesday, 20th October 2010, in Dublin. Click to enlarge.

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This will be my important message on Wednesday next, 20th October 2010, when I address the Institution of Fire Engineers (Ireland Branch) Annual Fire Conference … which will be held in the Dublin Fire Brigade Training Centre, Marino, Dublin 1 … beginning at 09.30 hrs in the morning.

Institution of Fire Engineers (Ireland Branch)

2010 IFE Annual Fire Conference Brochure

Click the Link Above to read and/or download PDF File (326kb)

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Three Powerful Pulling Forces for Change … or should I say Dragging Forces, with a lot of kicking and screaming involved (!) … will have a direct impact …

1.  Sustainable Design

The interior view shown below is not that of a Sustainable Building … but of a Modern Architectural Icon, designed by the Master Architect Mies van der Rohe towards the end of the 1920’s … way back in the last century !   Two innovative architectural concepts are elegantly illustrated in the photograph …

  • Open Planning – one space ‘flows’ into the next without interruption by a physical barrier … drawing the eye and encouraging movement.  In this particular building … a building of architectural, cultural and historical importance … any attempt to impose ‘fire compartmentation’ on the layout would be utterly ridiculous !
  • Separation of Building Structure & Fabric – notice the column in the foreground.  This is quite unlike the massive form of building construction in the past !

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Colour photograph showing an Interior View of the Barcelona Pavilion, designed by the German Architect Ludwig Mies van der Rohe in 1929. Photograph taken by CJ Walsh. 2009-03-20. Click to enlarge.
Colour photograph showing an Interior View of the Barcelona Pavilion, designed by the German Architect Ludwig Mies van der Rohe in 1929. Photograph taken by CJ Walsh. 2009-03-20. Click to enlarge.

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Fire Engineering is still trying to grapple … unsuccessfully … with innovative approaches, dating from the early part of the 20th Century, to Architectural Design.  In the 21st Century, Sustainable Design – not Green Design – involves a far more radical approach to Design, the use of Building Materials, and Construction.  In the face of this much greater challenge, Fire Engineering must begin to respond effectively … with creativity and imagination.  There is no other alternative !

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2.  Cul-de-Sac of Current Fire Engineering

Working in Building Control at the time … I encountered the Typical Building Detail shown below in an early 1990’s Dublin Hotel Extension Project … comprising a 10 metre span steel beam … with non-loadbearing steel stud partitioning beneath, separating a corridor from bedrooms … each with 1 Hour’s Fire Resistance.  During a fire and long before the period of 1 Hour has elapsed … that steel beam will have deflected by a considerable dimension.  What happens, then, to the non-loadbearing steel stud partition, below, and its fire resistance performance ???   This makes no sense.

Does current Fire Engineering have a robust rational and empirical basis … or is it just one remove from Voodoo and Witchcraft ??

Black and white 'concept' drawing, with a small touch of colour, showing a typical detail in an early 1990's Dublin Hotel Extension Project ... of a 10 metre span steel beam ... with non-loadbearing steel stud partitioning beneath, separating a corridor from bedrooms ... each with 1 hour's fire resistance ?!? Drawn by CJ Walsh.
Black and white ‘concept’ drawing, with a small touch of colour, showing a typical detail in an early 1990’s Dublin Hotel Extension Project … of a 10 metre span steel beam … with non-loadbearing steel stud partitioning beneath, separating a corridor from bedrooms … each with 1 hour’s fire resistance ?!? Drawn by CJ Walsh.

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3.  NIST(USA) Recommendations on the 9-11 WTC Building Collapses

Determined resistance by Vested Interests … a Lack of Institutional Capacity, i.e. failure to be able to properly anticipate, or to be adequately prepared, and/or to respond effectively and in a timely manner to major fire incidents … and a small element of the ‘Issue Attention Cycle’, where considerable investment in time and resources were necessary to make real progress on the issues thrown up by 9-11 but, unfortunately, governmental and public attention soon waned and dissipated … shifting to new problems, e.g. the Illegal Iraq ‘Crusade’ … have all contributed to a situation where there has been little in the way of substantive implementation of the Recommendations contained in the 2005 and 2008 NIST(USA) Reports on the 9-11 WTC Buildings 1, 2 & 7 Collapses … in the United States of America, Europe … or anywhere else.

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Colour photograph of the World Trade Center Complex in New York, taken at the time of the 2nd Plane Impact during the morning of Tuesday, 11th September 2001. Click to enlarge.
Colour photograph of the World Trade Center Complex in New York, taken at the time of the 2nd Plane Impact during the morning of Tuesday, 11th September 2001. Click to enlarge.

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That is not our approach, here, at FireOx International – the Fire Engineering Division of Sustainable Design International Ltd.  Instead, we have decided to present all of the NIST Recommendations … to our readers … in a Series of Posts on this Technical Blog.

Sustainable Fire Engineering HAS a robust rational and empirical basis !

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How ‘Sustainable’ are Built Environment Adaptation Projects ?

2010-04-01:  The Inter-Basin Water Transfer Project from Lough Ree, on the River Shannon, to Dublin City, in Ireland, has been described as a Pilot Adaptation Project on the United Nations Framework Convention on Climate Change (UNFCCC) WebSite Database relating to the Nairobi Work Programme (2005-2010).

I did not imagine this … please check out the listing, for yourselves, on this WebPage … www.unfccc.int/adaptation/nairobi_work_programme/knowledge_resources_and_publications/items/4555.php?sort=focus_sort&dirc=DESC&seite=1&anf=0&type=&region=&focus=&means=

Detailed information concerning the Project can be accessed and downloaded at this Irish Address:  www.watersupplyproject-dublinregion.ie   It will cost approximately €600 million (probably much more !) … devour many material resources and have an adverse environmental impact … the objective being to divert water from the Shannon, a large river in the mid-west of the country … to Dublin, the capital city, which is located over 100 kilometres away on the east coast … in order to deal with the expected shortage of water which will be caused, among other relevant factors, by future climate change.

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Colour image showing the many options for a future Dublin Region Water Supply Project ... linking the River Shannon, and its lakes, to the Capital City. Click to enlarge.
Colour image showing the many options for a future Dublin Region Water Supply Project ... linking the River Shannon, and its lakes ... to the Capital City, which is over 100 kilometres away on the east coast. Click to enlarge.

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BUT … just how Sustainable is this Climate Change Adaptation Project … if the following other relevant factors are considered ?????

1.  Since the 1960’s … a dysfunctional and corrupt Spatial Planning System in the Dublin City Region has actively encouraged an uncontrolled, urban and suburban horizontal sprawl to take place.  Today, this pattern of development remains unchecked.

2.  At this time, there are still no Residential Water Charges in Dublin.  The concept of water conservation is, therefore, almost unknown among householders.  National and local politicians are terrified by any prospect of having to vote in favour of imposing these necessary charges.

3.  There are enormous un-intended losses, i.e. Leaks, from the public mains potable/drinking water distribution system … approximately 40% even in the good times, and recently, well in excess of 60% following the National Snow Emergency in Ireland.

4.  Potable/drinking water supplied to houses in the Dublin City Region is not yet Metered.  There is no urgency, therefore, in locating and repairing water leaks which occur between the private property boundary of a house and the house itself.

5.  There is no existing legal requirement in Ireland’s National Building Regulations to Harvest Rainwater in any buildings, or on any hard surfaces in the vicinity of those buildings.  A current proposal to amend Technical Guidance Document H: ‘Drainage & Waste Water Disposal’ will merely present relevant guidance text to building designers concerning this option.

Furthermore, there is no effective System of Technical Control operated by the Local Authorities in the City Region … to enforce a legal requirement concerning rainwater harvesting … even if such a legal requirement were to be introduced !

6.  In 2005-2006, at the height of the Celtic Tiger Economic Boom … the existing Foul and Storm Water Drainage Infrastructure in the City Region was already stretched to keep pace with the ‘wild’ demands for new development land.  Detailed information concerning the Greater Dublin Strategic Drainage Study can be accessed and downloaded at this Irish Address:  www.dublincity.ie/WaterWasteEnvironment/WasteWater/Drainage/GreaterDublinStrategicDrainageStudy/Pages/RegionalDrainagePolicies-OverallPolicyDocument.aspx

Overloading of the existing drainage systems was evident from a marked deterioration in water quality, increased risks of flooding and pollution, and concerns that the drainage system and sewage treatment plants had insufficient capacity to cater for future development.

7.  Sustainability Impact Assessment (SIA)

‘ a continual evaluation and optimization assessment – informing initial decision-making, or design, and shaping activity/product/service realization, useful life and termination, or final disposal – of the interrelated positive and negative social, economic, environmental, institutional, political and legal impacts on balanced and equitable implementation of Sustainable Human & Social Development ‘

… is not yet a standard procedure, at any level, within national, regional and local Authorities Having Jurisdiction (AHJ’s).  If it were, the most glaring flaw in this project would rapidly be identified.  There is no comprehension at all, in the minds of Dublin City’s decision-makers, that water is a very valuable, but limited, resource !

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Although today is 1st April 2010 … far too many people in senior policy and decision-making roles are giving solemn, unquestioning consideration to this Project.

To be successful, however, National Adaptation Strategies, Programmes and Projects must be informed, in a meaningful way, by the concept of Sustainable Human and Social Development … and, prior to implementation, must be filtered through the lens of a comprehensive Sustainability Impact Assessment (SIA) !

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POSTSCRIPT

2011-09-29:  Relevant extract from the 2010 Annual Report of the Irish Comptroller and Auditor General Volume 2

WATER SERVICES EFFECTIVENESS

22.11  Funding for the provision of infrastructure for the supply of drinking water is provided by the Department of the Environment, Community and Local Government under two programmes.  Major water supply schemes are included in the rolling three-year Water Services Investment Programme (WSIP).  These schemes focus on the larger concentrations of population in urban areas.  Annual Rural Water Programmes (RWP) provide the bulk of funding for the construction of group water schemes and small public schemes in rural areas.

22.12  Over the period 2000-2010, €5.2 Billion of Exchequer resources have been invested in the upgrading and provision of new water services infrastructure, of which €4.2 Billion was spent on WSIP and €0.99 Billion was spent on RWP.  Overall expenditure includes investment of over €1 Billion on public water supply and networks and €168 Million on water conservation.  [The WSIP expenditure also includes €889 million relating mainly to the group water sector under the rural water programme.]  There are two key indicators of the effectiveness of expenditure on water supply and conservation:

  • the quality of drinking water;
  • the extent to which treated water reaches the consumer.

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Effectiveness of Water Supply System

22.17  Loss of output is a feature of all water distribution systems.  Unaccounted for Water (UFW) is a measure that is used to track this loss.  It is the difference between ‘net production’ which is the volume of water delivered into a network and ‘consumption’ measured in terms of the volume of water that can be accounted for by legitimate consumption.

22.18  Figure 109 shows UFW as a percentage of the net volume of water supplied for 2008 and 2009.  It sets out the national average performance and the range across local authorities.  Annex A contains the data on UFW for these two years for all county and city councils.

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Black and white image showing Figure 109: 'Unaccounted for Water (UFW) as a Percentage of Water Supplied, 2008-2009' ... from the 2010 Annual Report of the Irish Comptroller and Auditor General - Volume 2. Click to enlarge.
Black and white image showing Figure 109: 'Unaccounted for Water (UFW) as a Percentage of Water Supplied, 2008-2009' ... from the 2010 Annual Report of the Irish Comptroller and Auditor General - Volume 2. Click to enlarge.

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Black and white image showing Annex A: 'Unaccounted for Water (UFW) as a Percentage of Total Volume of Water Supplied, 2008 and 2009' ... from the 2010 Annual Report of the Irish Comptroller and Auditor General - Volume 2. Click to enlarge.
Black and white image showing Annex A: 'Unaccounted for Water (UFW) as a Percentage of Total Volume of Water Supplied, 2008 and 2009' ... from the 2010 Annual Report of the Irish Comptroller and Auditor General - Volume 2. Click to enlarge.

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22.19  Overall, the average percentage of UFW was approximately 41.48% in 2009, which showed a marginal increase over 2008 (41.20%).  Some 17 of the 34 authorities have seen an improvement in 2009, the most noticeable being a reduction in the percentage of water lost in Monaghan which was down by 27%, Cavan by 18% and Kilkenny by 15%.  The other 17 local authorities reported a disimprovement in the amount of UFW for 2009, with Limerick County Council reporting losses of 35%, up from 17% in 2008.  Fingal County Council, Limerick City Council, and Dublin City Council reported substantial increased leakage in 2009 over 2008 at 27%, 22% and 20% respectively.

Cost of Unaccounted for Water (UFW)

22.20  The cost of UFW is considerable for local authorities.  However, since the LGMSB does not collate information on water production and associated costs the data is not available in the Department of the Environment, Community and Local Government.  As a result, it is not possible in this report to provide an up-to-date estimate of the cost of UFW being experienced.

22.21  A value for money examination carried out in the mid-1990’s on water production and distribution showed that the cost per cubic metre of water produced varied between €0.14 to €0.39.  The study found that overall water leakage level in the authorities surveyed at that time ranged from 27% to 40% of total water produced.

22.22  The results of the study were based on estimates since none of the authorities that were the subject of the value for money examination had the means to measure accurately the level of overall leakage.

22.23  Based on its results, the examination reported that, for five local authorities reviewed at that time, the estimated annual production cost of the water lost due to leakages was in the order of €3.5 million.  Applying the Consumer Price Index to this value brings the cost to approximately €5.3 million in present-day terms.

22.24  As leakage is just one factor contributing to UFW, it appears from the losses now being recorded by local authorities that there has been little, if any, improvement in the situation despite the considerable State investment in water services in the interim.

Views of the Accounting Officer

22.25  The Accounting Officer informed me that under the National Water Conservation Sub-Programme, which commenced in 1996, the National Water Study undertook a comprehensive national water audit of all urban centres with populations exceeding 5,000 to determine the extent of UFW and leakage problems nationally.  The National Water Study examined the reasons for UFW and set out recommendations to reduce the levels of UFW.

22.26  Arising from the findings of the National Water Study and pilot water conservation schemes undertaken in the main urban centres of Dublin, Cork, Galway, Waterford and Limerick, water conservation strategies and operational programmes were adopted which have been rolled out nationally since 2003.

22.27  The Dublin Region Water Conservation Programme, which was carried out between 1998 and 2002 as one of the pilot schemes under the National Water Conservation Sub-Programme, reduced regional leakage from 47% to 28%.  UFW in the Dublin region now averages 30% which is amongst the lowest in the country.

22.28  Since the commencement of the water conservation sub-programme, substantial investment has been made in the fundamental infrastructure for water management, including the metering of supply input.  Also, the methodology has been standardised.  Arising from this, the reported figures now have an accuracy that the figures from earlier times could not have had.

22.29  By way of example, the Greater Dublin Water Supply Strategic Study (1996) estimated losses of 44% of total input, of which 39% was allocated to distribution losses and 5% allocated to customer losses.  When the metering infrastructure was checked and upgraded during the water conservation project (around 2000), it was found that the original meter readings for flow into supply were incorrect, and that losses were actually higher than originally thought (giving the corrected estimate for that time of 42% distribution losses and 47% in total).  Notwithstanding that the Dublin Region bulk metering infrastructure was considered reliable at the time, it was found to have inaccuracies that were subsequently corrected.

22.30  In terms of comparisons, the Accounting Officer pointed out that the Dublin supply is hugely significant, serving approximately one third of the population of the country.  Consequently, the Dublin supply region reduction of distribution loss from 42% to 30% currently must reflect positively on the national average (and it is the corrected Dublin Region figure from 1995/96 that is most reliably reflective of the situation at that time).

22.31  A further observation by the Accounting Officer was that without investment the leakage situation will deteriorate as assets age.  It follows that a certain level of investment is required even just to maintain the status quo.

22.32  The Accounting Officer stated that, outside of Dublin, most of the investment had been in water management systems, which while they had made a contribution to tackling leakage, were really the platform for the more intensive investment being rolled out for mains rehabilitation in the WSIP 2010-2012.  She said that this investment in water management systems had contributed to greater efficiency in the supply system, which had been demonstrated during the two severe winters and flooding in Cork, when authorities had been better able to manage the rationing of supply and restoration of supply than they would have been a decade ago.

22.33  Finally, the Accounting Officer said that the need to focus on water conservation had been demonstrated through the development of service indicators, training in water conservation, development of guidance and work with the County and City Managers Association to streamline the approaches and accelerate work in this area.

CONCLUSION – Effectiveness of Water Supply System

UFW arises from factors such as leakage, poor service connections and metering errors.  Average UFW levels in Ireland appear to be at levels twice the OECD average of 20%.  While some caution needs to be applied in interpreting the results of a limited examination of water leakage carried out over 15 years ago, present-day losses may be, in many local authorities, as high as those found in the mid-1990’s, notwithstanding an investment of over €1 Billion in water supply and conservation in the last ten years.

In the light of the potential cost of UFW it is necessary that the factors that give rise to UFW be reviewed and strategies and operational programmes to address the underlying issues contributing to the problem be re-evaluated.

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The Recent Major Emergency Response Fiascos in Ireland

Unless you have been living, for the past two or three months, in conditions similar to a detainee in the illegally occupied part of Cuba, called Guantánamo Bay … and you have been deprived of almost all sensory perception … you cannot have escaped (!) the fact that we have had a Major National Flood Emergency … followed by a Major National Snow Emergency … followed, again, by a National Flood & Water Emergency.  I kid you not !!!   But … the emergencies haven’t yet ended.  And … it’s not just the politicians … at national and local levels … who should bury their heads in shame.

It has been amply demonstrated that the relevant emergency-related institutions in this country are incompetent, disorganized and dysfunctional.  Focus your venomous attentions, as well, on the civil and public servants, administrative and technical staff, and private sector technical consultants who occupy space in these institutions.

Did you know that we actually have a National Directorate for Fire & Emergency Management (NDFEM), which is located deep within the Custom House … in the centre of Dublin City.  According to the NDFEM, a Major Emergency is …

‘ An incident which, usually with little or no warning, causes or threatens death or injury, serious disruption of essential services or damage to property, the environment or infrastructure … beyond the normal capabilities of the principal emergency services (An Garda Síochána, the Ambulance Service and the Fire Service) in the area in which the event occurs.’

Pages dedicated to NDFEM can be found on the Department of the Environment, Heritage & Local Government (DEHLG) WebSite … www.environ.ie

From the DEHLG HomePage, follow the link to the National Directorate for Fire & Emergency Management.

Please read … without laughing, crying, screaming out loud in utter frustration, or any combination thereof … about the NDFEM’s Mandate and Structure here … www.environ.ie/en/LocalGovernment/NationalDirectorateforFireandEmergencyManagement

Then … and only if you are brave enough … check out the Bozos, Wasters and Lúdramáns who sit on the NDFEM’s Management Board here … www.environ.ie/en/LocalGovernment/NationalDirectorateforFireandEmergencyManagement/ManagementBoard … and the NDFEM’s Consultative Committee here … www.environ.ie/en/LocalGovernment/NationalDirectorateforFireandEmergencyManagement/ConsultativeCommittee

Prize specimens !   At least we can get rid of politicians at the next elections !!

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Older People in Emergencies – Action & Policy Development (II)

2009-11-25:  In 2008, the World Health Organization (WHO) Report: ‘Older People in Emergencies – Considerations for Action & Policy Development’ was published.

The following are short extracts from that Report …

Older People

Until recently, older peoples’ needs in disasters and conflicts were addressed only by broader adult health and humanitarian programmes.  This has changed, as several recent emergencies highlighted this population’s vulnerabilities.  Of the 14,800 deaths in France during the 2003 heat wave, 70% were people over 75 years of age.  Of the estimated 1,330 people who died in the wake of Hurricane Katrina, most were older people.  In Louisiana, 71% of those who died were older than 60 years;  47% of this group were over 77 years old.  Worldwide, the United Nations High Commissioner for Refugees (UNHCR) has estimated that older people make up 8.5% of the overall refugee population, and in some cases comprise more than 30% of caseloads.  In 2005, approximately 2.7 million people over the age of 60 were living as refugees or internally displaced persons.

Globally, the proportion of older people is growing faster than any other age group.  In 2000 one in ten, or about 600 million, people were 60 years of age or older.  By 2025, this figure is expected to reach 1.2 billion people, and in 2050 around 1.9 billion.  In developing countries, where 80% of older people live, the proportion of those over 60 years old in 2025 will increase from 7% to 12%.  Moreover, life expectancy at birth has increased globally from 48 years in 1955 to 65 in 1995, and is projected to reach 73 in 2025.  By 2050, people over 80 years old are expected to account for 4% of the world’s population, up from 1% today.

Disability & Older People

Worldwide, it is estimated that more than 80% of the disabled population lives in developing countries, where the prevalence of disability is approximately 20%.  That rate is expected to increase dramatically as populations age.  By 2050 in India, the incidence of disability is expected to jump by 120%, in China by 70% and in sub-Saharan Africa by 257%.

Emergency Planners must consider these trends, because poor health and reduced mobility increase the risk of serious injury and illness in disasters.  Older people have sustained more injuries in disasters than other groups because of functional limitations such as poor balance, muscle weakness and exhaustion.  Older people have higher rates of coronary heart disease, diabetes, stroke, cancer, respiratory diseases and rheumatism.  A study in China found that 74% of those over 80 years old had chronic diseases, 1.5% were physically disabled, and 3.46% had Alzheimer’s disease.  In Iraq, more than half of 340 older people surveyed by HelpAge International had chronic joint and bone problems, hypertension, heart problems, diabetes and reduced eyesight and hearing.  In West Darfur, Sudan, 34% of surveyed refugees 50 years of age and over were disabled, 27% could not move without help and 19% had severely impaired vision; while 61% reported chronic diseases that required specialized treatment and/or medicines that were not available.

Objective 1:   Increase Visibility and Raise Awareness among Health Agencies and Humanitarian Organizations about Older Peoples’ Needs and Priorities in Emergencies.

  • Mainstream and integrate issues related to older people and emergencies into existing policies and guidelines (i.e. emergency medicine, nutrition, protection, gender-based violence, participatory assessments and programming).  Include plans for older people in national policy and guideline documents.
  • Highlight the need to assist and protect older people as well as their capacities and contributions in rebuilding affected communities.
  • Develop inter-agency efforts to identify gaps, develop practice guidelines and provide training and education.
  • Promote better practice policies and documents among all stakeholders.
  • Collaborate with funders to increase humanitarian assistance to older people based on needs assessments and reflect these in funding proposal criteria.
  • Involve older people in developing emergency management activities to increase their visibility and ensure their needs are taken into account, for example, in shelter plans and locations.

Objective 2:   Develop Essential Medical and Health Resources for Older People in Emergency Practices.

  • Identify and include essential medicines for older people in emergency kits.  Include medicines for chronic diseases and other illnesses common among this social group.
  • Develop disability aid packages with equipment such as eyeglasses and walking sticks.
  • Develop education modules for health professionals on diseases common among older people, including HIV/AIDS.
  • Develop and disseminate guidelines for geriatric medicine in emergencies and humanitarian crises.
  • Within the health care system, ensure that conditions and needs common to older people are integrated into patient triage, clinical evaluation, treatment, the emergency medical response system and access to specialty care.
  • Ensure that nutritional guidelines for food distribution suitable for older people are integrated into health planning and response plans.
  • Ensure local development of guidelines for feeding older people, using locally available foods to the extent this is possible where populations depend on external food aid.
  • Implement gender-based analyses in planning and programme design to account for differences between older men and women in terms of both health needs and access issues.

Objective 3:   Develop Emergency Management Policies and Tools to Address Older Peoples’ Health-Related Vulnerabilities.

  • Integrate older peoples’ health needs and related issues into assessment tools and practices.
  • Develop community-based tools using disaggregated data to identify vulnerable older people.  Include formats to identify chronic health conditions, disabilities and nutritional needs.
  • Develop procedures to identify hidden and stay-behind older people.
  • Develop standardized tools to assess support needs of older people, including inter-generational and community care options.
  • Develop age-friendly standards and guidelines so that service and care environments are accessible to older people with disabilities.
  • In collaboration with older people, their families and communities, develop personal and household preparedness kits in areas of predictable disasters.
  • Collaborate with communities in identifying and implementing community-based home care and support strategies which may reduce older peoples’ isolation and vulnerability during crises.
  • Develop guidelines and evacuation plans that include mechanisms to identify and transport frail, disabled and older people with special medical conditions.  Identify procedures to ensure adequate care and treatment as necessary.
  • Develop guidelines to ensure safe and adequate treatment of older people in evacuation centres and refugee camps.
  • Ensure that health facilities have feasible plans to care for older people during disasters and humanitarian crises.
  • Develop monitoring and evaluation tools to measure the performance of health care services and humanitarian interventions targeting older people.  These measures should be integrated into existing monitoring and evaluation procedures where possible.

Objective 4:   Ensure that Older People are Aware of and Have Access to Essential Emergency Health Care Services.

  • Use established assessment tools to identify and locate frail and disabled older people and those with chronic diseases and special medical conditions, as well as older caretakers of orphaned children.
  • Ensure that assessments are participatory and target all older populations.  Assessments should include information on health conditions, social support needs, caretaking responsibilities and available means to meet basic living needs, including access to food and health services, treatment and medicines.
  • Ensure that assessments are coordinated across primary health care, rehabilitation, long term care and social services to meet the needs of older people.
  • Implement outreach services and referral mechanisms to identify and ensure care for hidden or stay-behind older people.
  • Coordinate primary health care, rehabilitation, long-term care and social services to establish system referral mechanisms that older clients may require.
  • Assess and organize training for health staff to ensure knowledge of geriatric nutritional, health and medical care needs.
  • Establish information programmes to educate older people, families and caregivers about nutritional needs, medical conditions and health care options.
  • Use disaggregated data to assess services by age and gender.

Objective 5:   Provide Age-Sensitive and Appropriate Health and Humanitarian Services to Maintain Older Peoples’ Health.

  • Ensure that equitable access to shelter, clothing, food and sanitation prevent deterioration of health through integrated individual assessments and referrals to health and humanitarian agencies.
  • Ensure that age-friendly practices are used to promote services to older people with disabilities.
  • Provide access to appropriate health care, including medicines for chronic diseases and disability/restorative aids.
  • Collaborate with communities in identifying community-based home care and support options for frail and disabled older people.
  • When appropriate and feasible, develop mobile clinics to extend health services to older people living in remote locations.
  • Implement mechanisms to assess nutritional balance and ensure access to supplementary food programmes when appropriate, taking into account that many older people also care for children.  Provide education on food preparation using supplementary or locally available foods.
  • Ensure that protection needs of older people are integrated into programming (e.g. social welfare or community services) to identify persons at risk and prevent abuse and exploitation.
  • Undertake monitoring to assess continuing effectiveness of services to older people.
  • Use disaggregated data to assess efficiency of implemented activities by age and gender.

Objective 6:   Promote Cross-Sectoral Planning and Co-Ordination to Raise Awareness of Older Peoples’ Needs in Crises and Reduce Their Risk of Marginalization and Deteriorating Health in Emergencies.

  • Raise awareness among agencies and organizations concerning physical and health issues specific to older people and of ways to adapt basic need support to their requirements (e.g. supplementary food rations, livelihood needs and impacts of protection issues on older peoples’ physical and psychological health).
  • Where possible, include older people in planning and programming committees to increase their visibility and ensure their needs and priorities are integrated.
  • In coordination with appropriate partners, establish community self-help groups to facilitate community care for more vulnerable older people.
  • Recognize self-sufficiency as key to maintaining health and encourage the inclusion of older people in training programmes, income-generation schemes, and community development projects.
  • Establish older peoples’ committees to facilitate self-advocacy and communication with authorities and ministries of health to increase access to existing services and entitlements.

Objective 7:   Build Institutional Capacity and Commitment towards Ensuring the Health and Safety of Older People in Emergencies.

  • Integrate cross-cutting health emergency management issues into global/regional/country strategic plans.
  • Promote inter-agency and cross-sectoral consultation on cross-cutting policy and programming issues to build consensus, commitment and capacity to respond to older peoples’ needs in disasters and humanitarian crises.
  • Collaborate with ministries of health to establish mandates and legislation ensuring the provision of care to older people; apply a human rights framework to these issues.
  • Collaborate with ministries of health to develop options to increase older peoples’ access to affordable health care services, including the implementation of subsidized medical and medicine programmes.
  • Advocate for enhanced funding and humanitarian assistance to older people in emergencies and conflicts.  Encourage funding agencies to recognize older people as a priority.
  • Develop frameworks to promote participatory, transparent and accountable processes to advance the needs of older people.
  • Develop sustainable mechanisms to maintain advocacy and consultation of older people within the health care-system.  Establish and involve advocacy committees in the planning, implementation and evaluation of emergency management practices when appropriate, for example regarding the design of community shelters that may be accessed by older disabled people.

Objective 8:   Strengthen the Capacity of Ministries of Health and Health Care Systems to Meet the Needs of Older People in Emergencies.

  • As required, integrate the medical and nutritional needs of older people into local public health and emergency preparedness and response strategies.
  • Develop strategies to ensure that existing health care systems develop capacity (infrastructure and knowledge) to meet the increasing proportion of older people who will be impacted by disasters in the future, taking into account medical, disability and mental health needs, including dementia and Alzheimer’s disease.
  • Collaborate with communities in identifying community-based home care and support strategies for older people as an option to reduce older peoples’ isolation and vulnerability to disasters.
  • Collaborate with communities to develop and maintain disaster reduction committees.  Assist in the implementation of strategies to strengthen community support to older people and reduce their levels of risk during disasters (e.g. development of community emergency response teams or mutual assistance groups among more vulnerable older people).
  • Integrate older peoples’ needs into exercise designs and facilitate the dissemination of lessons learned.
  • Develop performance frameworks and monitoring mechanisms to assess medical response systems and older peoples’ access to specialty care in emergencies.

Objective 9:   Develop Mechanisms to Ensure Continuing Development and Exchange of Expertise as these Relate to Older People in Emergencies.

  • Develop and provide ongoing training and education to staff on the needs and priorities of older people, including responsibility to include this population in planning and policy development.
  • Integrate issues related to older people in emergencies into relevant university curricula.
  • Undertake comparative research to assess the health status (including access to assistance) of older people in emergencies vis-à-vis other age groups.
  • Undertake research to address demographic shifts and the increasing proportion of older people in disasters as this relates to health care and infrastructure/facility development.
  • Ensure emergency preparedness and response considerations are integrated into relevant services and institutions (e.g. facilities caring for frail and disabled older people are required to develop and practice evacuation and emergency care plans).

Objective 10:   Promote Active Ageing as a Strategy to Reduce Vulnerability and Develop Resiliency to Disasters.

  • Promote a wider understanding among ministries of health and humanitarian organizations of the economic and social factors contributing to the vulnerability of older people, including issues related to livelihoods, inter-generational dependence and social pension.
  • Develop policies that recognize active ageing and resiliency as facilitating older peoples’ capacity to prepare for, cope with and respond to the affects of disasters and conflicts.
  • Include a life course perspective that recognizes health promotion and prevention of disease and disability.
  • Support cross-sectoral forums and activities which link the risks of older people in emergencies to frameworks for livelihoods, protection and gender-based equality, health promotion and social pension.
  • Collaborate with relevant organizations to mainstream the health needs of older people into existing humanitarian programmes addressing shelter, nutrition, livelihoods, protection and gender-based violence.
  • Develop information campaigns and encourage media to highlight both the needs and capacities of older people and to increase their visibility.
  • Collaborate with funding bodies to integrate active ageing as a criterion in funding proposals targeting older people.

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Disability Access Certificates (DAC’s) – A Time to Worry ? (I)

2009-10-17:  Some of you are already hitting the Internet Search Engines … with fierce intent altogether … about  Disability Access Certificates (DAC’s) !

Is it Time to Panic ?   No.

For a simple and direct hit, the 2 most relevant Irish Legal Instruments are:

1.  Statutory Instrument No. 352 of 2009 – Building Control Act 2007 (Commencement) Order 2009.

This states …

” The 30 September 2009 is appointed as the day on which the provisions of Sections 5 and 6 of the Building Control Act 2007 shall come into operation.”

Section 5 covers the Amendment of Section 6 (Building Control Regulations) of the Building Control Act 1990.

Section 6 covers the Amendment of Section 7 (Appeals) of the Building Control Act 1990.

2.  Statutory Instrument No. 351 of 2009 – Building Control (Amendment) Regulations 2009.

This states …

” These Regulations shall come into effect on 1 October 2009, except for the provisions of Article 8 which shall come into effect on 1 January 2009.”

Article 8 covers Disability Access Certificates and Revised Disability Access Certificates.

For you, yourself, to properly examine all of the ‘ins and outs’ of this New Certification Scheme … download the PDF File below … and then search the document (making sure that it is not case-sensitive !) using the phrase ‘Disability Access Certificate’.  You will find 99 instances where the phrase is used.

Enjoy !

Ireland: Statutory Instrument No. 351 of 2009 – Building Control (Amendment) Regulations 2009

Click the Link above to read/download PDF File (223 Kb)

In order to make full sense of all that is happening, and is intended to happen in the not too distant future … there are a few other Legal Instruments, related to the two listed, which also need to be consulted … but that is an exercise meant for masochists !

In comparison, the European Union Lisbon Treaty was a sweet bedtime story !   Seriously !!

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Is it Time to Worry ?   Yes.

Here are just a few random ideas for your cogitation …

  • If the Department of the Environment, Heritage & Local Government (DEHLG) pays little heed to Submissions made during and after this summer’s ‘consultation’ process … the proposed New Technical Guidance Document M: ‘Access & Use’ will end up looking like a real dog’s dinner of an absolute mess !   FUBAR.

Years were spent in the preparation of the New TGD M.  When it does eventually appear, it will be an accurate reflection of technical capacities within both the Department and the National Disability Authority (NDA).

Deeply regretted is the absence of Mr. Kevin Spencer … a gentle soul … from the DEHLG.  Things have not been the same since his departure.  He knew what he was talking about.

  • Who will deal, at a technical level, with Applications for Disability Access Certificates in the Local Authorities ?   Will they be competent to do so ?   Will their interpretation of the Part M Legal Requirements be harmonized … not just with other/different Authorities … but even with other technical personnel in the same Authority ???
  • In order to make this new certification scheme work, will the Guidance Text in Technical Guidance Document M (whatever version appears !) be operated as if it were Prescriptive Regulation … which will be totally illegal ?

This has been exactly the story … for many years … with the Guidance Text in Technical Guidance Document B … in the course of operation of the Fire Safety Certification Scheme.  FUBAR.

  • If, as I hinted above, the proposed New Technical Guidance Document M: ‘Access & Use’ will be a real dog’s dinner of a mess … falling far short of what can now be reasonably described as minimal accessibility performance (see the Draft International Accessibility-for-All Standard ISO 21542) … this will certainly open Building Owners/Managers of newly completed buildings to Complaints under Irish Equality Legislation.  Why is the Disability Sector so inactive with regard to making complaints ?

and finally …

  • Are the relevant Irish Decision Makers, as I suggested might happen in a previous post, in the process of actually sleepwalking into an unquestioned acceptance of the inadequate British Standards BS 9999 : 2008 and BS 8300 : 2009 ???   Do they know how to do anything else ?

 

For some sublime moments of meditation, however, please chew on the information provided at these Pages on the SDI Support WebSite

Disability Rights & Removing Physical Restrictions on Participation in Society ;

Towards a Sustainable Social Environment, Accessibility-for-All & Facilitation Design (2001 WHO ICF) ;

Fire Evacuation-for-All & Principles of Fire Engineering.

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

2009-06-08:  The other day, I received an impassioned e-mail … an extract …

 

” We are an energy rating company involved in a campaign for enforcement.  Yesterday, we made a presentation to SEI (see attached).  It was the result of a 2-month attempt to meet with the DEHLG and SEI.  You are right in your article about them ‘not WANTING to know’.

 

My only question is: do you have any ideas on what’s next ? ”

 

 

 

The BER Gold Rush Soap Opera so far …

 

There are thousands of BER Assessors out there around the country … each having paid a ‘pretty penny’ for training, for exams, and for registration … and work on the ground is very scarce.  A significant number of those Assessors have an inadequate understanding of building construction … while some of the people who are involved in providing Validated BER Training Courses are, to put it mildly, similarly unendowed.

 

Energy Ireland (SEI) is the Issuing Authority, but it has absolutely no experience as a Control Authority.  And has anyone bothered to read the relevant Legal Disclaimer on the SEI WebSite ?   It does, however, have a large marketing budget … those smarmy, wall-to-wall radio advertisements, which refer to the ‘property game’, continue to irritate my sensitive ear drums !

 

Apparently … 20% of BER Assessments are turning out to be faulty, i.e. they have not been properly carried out by Registered BER Assessors.  In other words, 1 out of every 5 BER Certificates needs to be thrown in the paper recycling bin.  Furthermore … I have discussed in one of my first posts how there is only a very tenuous relationship between a BER Certificate and the ‘real’ energy performance of a specific building.  And in relation to ‘real’ buildings … there is a general non-compliance rate of 70% on Irish Building Sites with the minimal energy performance requirements in Part L of the Irish Building Regulations.

 

SEI’s Register of BER Assessors is unreliable.

 

What a magnificent waste of time, energy and money !

 

 

 

Some Comments on a Recent BER Certificate … 

 

Sitting on the desk to the left of my computer keyboard is a recent Building Energy Rating (BER) Certificate and its accompanying Advisory Report … issued sometime during the second half of May 2009 … for a private, single-occupation dwelling house somewhere in Leinster … and using the DEAP Version 3.0.0 computer software.  I do not wish to identify the specific Certificate.

 

This particular BER Certificate Documentation comprises:

 

         the actual BER Certificate ;

 

Can I be sure that the correct choices were made with regard to the software input information/data ?   No.

 

         its accompanying BER Advisory Report.

 

Not missing any marketing trick, and in stark contrast to the actual BER Certificate … there is an Energy Ireland (SEI) Logo at the top of the first page of the Advisory Report … and an elaborate footer with SEI contact information on the last page.

 

Meanwhile, there is not one single mention of Statutory Instrument No. 666 of 2006: European Communities (Energy Performance of Buildings) Regulations 2006 anywhere in the Report … nothing to explain that SEI is the Issuing Authority for the purposes of this national legislation … or that there is such a thing as a BER Register … etc, etc, etc.

 

The Advisory Information provided in the Report is too vague to be useable … and there are silly typographical errors.

 

Did the BER Assessor request any information from the owner about the house ?   It is impossible to tell whether he/she made any such request.

 

Am I assured that the BER Assessor had an adequate understanding of building construction ?   Definitely not.

 

[ Specific comments about other issues might identify the actual BER Certificate. ]

 

 

 

What’s Next ?

 

The following remarks are directed at those BER Assessors, building owners, landlords, building professionals and general punters who do wish to spend their money on something worthwhile … something which has meaning, and is useful.

 

Energy Labelling of Buildings, just as in the case of other energy using/consuming industrial products … is positive and very worthwhile.

 

The legal basis established by European Union (EU) Directive 2002/91/EC of the European Parliament and of the Council, of 16 December 2002, on the Energy Performance of Buildings … is a good start.

 

I would much prefer if this Directive were linked in more directly to the Extensive Framework of the Construction Product Directive … EU Council Directive 89/106/EEC, of 21 December 1988, on the Approximation of Laws, Regulations and Administrative Provisions of the Member States relating to Construction Products.  The reason that this has not already happened is because of a startling lack of horizontal integration between the different Directorates-General in the European Commission.

 

If there are problems with how the BER Legislation is operating at national level in Ireland, it is not the fault of Brussels or Directive 2002/91/EC … it is our problem … and it is up to us to remedy the situation.

 

There are 3 Immediate Priorities for Building Energy Rating in Ireland:

 

         increase accuracy ;

         reduce uncertainty ;

         improve reliability.

 

 

 

An Initial Proposal

 

Without amending any legislation … and without reference to the Department of the Environment, Heritage & Local Government (DEHLG), Energy Ireland (SEI) and the Construction Industry Federation (CIF) … none of which have shown any proper leadership in relation to these issues, but seem interested only in playing games …

 

 

1.  The BER Certificate

 

Attach a Single-Page Appendix to the actual BER Certificate which clearly shows the Input Information/Data selected by the Registered BER Assessor.  Include a Statement of Measurement/Calculation Uncertainty concerning the Energy Rating Process … and a Statement of Competence in Building Construction, with the Assessor’s Signature … at the bottom of the page.

 

Show the Page Number on the Certificate as Page No.1 of 2 … and on the Appendix as Page No.2 of 2.

 

A BER Certificate should not be valid without this Appendix.

 

 

2.  The Accompanying BER Advisory Report

 

Generally … tighten up the information provided in the Report, make it easier to understand … and make it more useable !   DO NOT TIE energy performance, or any other aspects of building performance, to the minimal – ‘abysmal’ – performance targets described in the guidance texts of Technical Guidance Documents A-M in the Irish Building Regulations.  We have to aim much, much higher !!   The European Union’s 2020 Climate Change Targets will be heavy going for Ireland, even if there is no agreement in Copenhagen at the end of 2009.  And … insert Page Numbers !!!

 

Include Additional Components in the BER Advisory Report:

 

         Findings of a Formal Interview/Questionnaire Survey with the building owner, landlord or manager – some questions should have an open format ;

         Results of Infra-Red Thermography and Air Seepage Testing – discussed at length in previous posts ;

         Results of a Radon Test – as already discussed, an important indicator of Indoor Air Quality and whether or not there is adequate Ventilation in the building.

 

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