Energy Ireland (SEAI)

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.


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.


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).


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.


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.




Buildings of Historical, Architectural & Cultural Importance !

2009-10-08:  Deeply interested … and ‘luuuving’ … a hands-on and direct involvement in the Sustainable Restoration of Buildings which are of Historical, Architectural or Cultural Importance … or even those buildings which are not so important … I am deeply frustrated and angry when I look around at what has happened … and continues to happen … in Ireland … horrible, damaging interventions and alterations of all kinds … too many of which cannot be undone.

Certain guru-like organizations and individuals must be robustly challenged !

Yes … in everyday practice, there are pressures concerning an improvement of energy performance (BER Certificates !) … an improvement of accessibility performance for people with activity limitations (2001 WHO ICF) … an improvement of fire safety performance, etc., etc. … and, in the next few short years, adaptation to climate change will require serious attention.

BUT – BUT – BUT … in dealing with these buildings (a priceless heritage for our children, and their children, which cannot be replaced !) … some absolutely core principles must influence the minds of decision-makers in client and construction organizations, national authorities having jurisdiction, regulators … and, most importantly, the minds and souls of architects and engineers.  (I am wondering … do engineers have souls ?)


ICOMOSInternational Council on Monuments & Sites / Conseil International des Monuments et des Sites – works for the conservation and protection of cultural heritage places and is the only global, non-governmental organization of its kind.  It is dedicated to promoting the application of theory, methodology, and scientific techniques to the conservation of the architectural and archaeological heritage.  Its work is based on the principles enshrined in the 1964 International Charter on the Conservation and Restoration of Monuments and Sites (Venice Charter).

From practical experience, I have found the 16 Principles of the 1964 Venice Charter to be enormously helpful …

ARTICLE 1    The concept of an historic monument embraces not only the single architectural work but also the urban or rural setting in which is found the evidence of a particular civilization, a significant development or an historic event.  This applies not only to great works of art but also to more modest works of the past which have acquired cultural significance with the passing of time.

ARTICLE 2    The conservation and restoration of monuments must have recourse to all the sciences and techniques which can contribute to the study and safeguarding of the architectural heritage.

ARTICLE 3    The intention in conserving and restoring monuments is to safeguard them no less as works of art than as historical evidence.

ARTICLE 4    It is essential to the conservation of monuments that they be maintained on a permanent basis.

ARTICLE 5    The conservation of monuments is always facilitated by making use of them for some socially useful purpose.  Such use is therefore desirable but it must not change the lay-out or decoration of the building.  It is within these limits only that modifications demanded by a change of function should be envisaged and may be permitted.

ARTICLE 6    The conservation of a monument implies preserving a setting which is not out of scale.  Wherever the traditional setting exists, it must be kept.  No new construction, demolition or modification which would alter the relations of mass and colour must be allowed.

ARTICLE 7    A monument is inseparable from the history to which it bears witness and from the setting in which it occurs.  The moving of all or part of a monument cannot be allowed except where the safeguarding of that monument demands it or where it is justified by national or international interest of paramount importance.

ARTICLE 8    Items of sculpture, painting or decoration which form an integral part of a monument may only be removed from it if this is the sole means of ensuring their preservation.

ARTICLE 9    The process of restoration is a highly specialized operation.  Its aim is to preserve and reveal the aesthetic and historic value of the monument and is based on respect for original material and authentic documents.  It must stop at the point where conjecture begins, and in this case moreover any extra work which is indispensable must be distinct from the architectural composition and must bear a contemporary stamp.  The restoration in any case must be preceded and followed by an archaeological and historical study of the monument.

ARTICLE 10    Where traditional techniques prove inadequate, the consolidation of a monument can be achieved by the use of any modem technique for conservation and construction, the efficacy of which has been shown by scientific data and proved by experience.

ARTICLE 11    The valid contributions of all periods to the building of a monument must be respected, since unity of style is not the aim of a restoration.  When a building includes the superimposed work of different periods, the revealing of the underlying state can only be justified in exceptional circumstances and when what is removed is of little interest and the material which is brought to light is of great historical, archaeological or aesthetic value, and its state of preservation good enough to justify the action.  Evaluation of the importance of the elements involved and the decision as to what may be destroyed cannot rest solely on the individual in charge of the work.

ARTICLE 12    Replacements of missing parts must integrate harmoniously with the whole, but at the same time must be distinguishable from the original so that restoration does not falsify the artistic or historic evidence.

ARTICLE 13    Additions cannot be allowed except in so far as they do not detract from the interesting parts of the building, its traditional setting, the balance of its composition and its relation with its surroundings.

ARTICLE 14    The sites of monuments must be the object of special care in order to safeguard their integrity and ensure that they are cleared and presented in a seemly manner.  The work of conservation and restoration carried out in such places should be inspired by the principles set forth in the foregoing articles.

ARTICLE 15    Excavations should be carried out in accordance with scientific standards and the recommendation defining international principles to be applied in the case of archaeological excavation adopted by UNESCO in 1956.

Ruins must be maintained and measures necessary for the permanent conservation and protection of architectural features and of objects discovered must be taken.  Furthermore, every means must be taken to facilitate the understanding of the monument and to reveal it without ever distorting its meaning.

All reconstruction work should however be ruled out ‘a priori’.  Only anastylosis, that is to say, the reassembling of existing but dismembered parts can be permitted.  The material used for integration should always be recognizable and its use should be the least that will ensure the conservation of a monument and the reinstatement of its form.

ARTICLE 16    In all works of preservation, restoration or excavation, there should always be precise documentation in the form of analytical and critical reports, illustrated with drawings and photographs.  Every stage of the work of clearing, consolidation, rearrangement and integration, as well as technical and formal features identified during the course of the work, should be included.  This record should be placed in the archives of a public institution and made available to research workers.  It is recommended that the report should be published.


Note on BER Certificates for Historical Buildings in Ireland

Unless and until that magnificent marketing and public relations firm … Energy Ireland (SEAI) … can openly show that the DEAP Software has been properly modified to handle buildings of historical, architectural or cultural importance … and this modification is fully transparent … Building Energy Rating (BER) Certification for these building types must be put on hold.




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