Energy Ireland (SEI)

BER Certificates & New Improvements to French DPE System

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

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

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

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

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

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

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

Un Outil Apprécié des Français

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

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

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

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

6 Mesures pour une Etiquette Energétique Fiabilisée

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

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

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

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

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

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

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

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

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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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Sustainable Climate Adaptation – The Post Copenhagen Priority !

[It was necessary to commence this post … only after visiting India.  See the first post of 2010-01-18.]

Well … we really saw it all at Copenhagen during those two long weeks in December 2009.  Wasn’t it great to watch ?!?   News, gossip, political ’shenanigans’ and spin … along with riots in the streets and walk-outs in the corridors … a veritable circus … an unmitigated farce !!!   A crime against humanity ????

Following the UNFCCC Summit … the PEW Center on Global Climate Change, in the USA (using their own words: an independent, non-profit, non-partisan organization dedicated to providing credible information, straight answers, and innovative solutions to address climate change), offered this ‘credible information’ …

‘ A new political accord struck by world leaders at the U.N. Climate Change Conference in Copenhagen provides for explicit emission pledges by all the major economies – including, for the first time, China and other major developing countries – but charts no clear path toward a treaty with binding commitments.

The basic terms of the Copenhagen Accord were brokered directly by President Obama and a handful of key developing country leaders on the final day of the conference, capping two weeks of harsh rhetoric and pitched procedural battles that made the prospect of any agreement highly uncertain.  It then took nearly another full day of tense negotiations to arrive at a procedural compromise allowing the leaders’ deal to be formalized over the bitter objections of a few governments.

… ‘

Now compare this News Article, by Satyen Mohapatra, from the Hindustan Times, New Delhi, India … dated Saturday, 9th January 2010 …

India Brought China Onboard at Copenhagen

New Delhi: Environment & Foreign Minister Jairam Ramesh, on Friday, said India had brought China onboard at Copenhagen.

“India brought China onboard at Copenhagen.  The U.S. actually owes a lot to India”, he said here at an interaction.

Despite taking a leadership role during the negotiations, Ramesh said, the Chinese were not ready to talk directly with the US, but always as part of the BASIC (Brazil, South Africa, India and China) Group.

Recounting how the Accord was reached at Copenhagen, Ramesh said it was “floundering on three issues: whether the goal of arresting greenhouse gas (GHG) emissions by 2050 should be expressed in terms of temperature or emission reduction or concentration of GHG in the atmosphere; what would be the international monitoring and verification regime for the mitigation actions of the BASIC countries; and whether the Accord would be legally binding”.

“We got 2.5 out of three”, he added.

And then … consider the opening of a statement by Bruno Rodriguez Parrilla, Cuban Minister for Foreign Affairs, at the last session of the Climate Summit on Friday, 18th December 2009 …

Mr. Chairman:

It has been four hours since President Obama announced an agreement that does not exist.  He is disrespecting the international community and behaving as an imperial master.

The document that you, Mr. Chairman, repeatedly claimed that did not exist is showing up now.  We have all seen drafts surreptitiously circulated and discussed in secret meetings, outside the rooms where the international community has been transparently negotiating through its representatives.

As it happens, Mr. Chairman, the non-existent document does exist.  I deeply regret the way you have conducted the works of this conference.

I can anticipate that the delegation from the Republic of Cuba has decided not to accept the declaration you are introducing.  I do not need any additional consultation in any other framework or format; therefore, I declare that at this conference there is no consensus on this document.

I add my voice to that of the representatives of Tuvalu, Venezuela and Bolivia.  Cuba considers the text of this apocryphal draft extremely insufficient and inadmissible.  The unacceptable goal of 2 degrees Centigrade would have incalculable catastrophic consequences, particularly for the small island nations.  It would also have a grave impact on numerous species of the biodiversity.

The document that you are unfortunately introducing contains no commitment whatsoever on the reduction of greenhouse gas emissions.

I am aware of the previous drafts, which again through questionable and clandestine procedures, were negotiated in small groups and which at least made reference to a 50% reduction by 2050.  I have here with me those previous drafts that it would be worthwhile making public in this room and releasing to the media and the representatives of the civil society.

The document that you are introducing now leaves out precisely those already meagre and insufficient key phrases contained in those drafts.  This document does not guarantee, in any way, the adoption of minimal measures conducive to the prevention of an extremely grave catastrophe for the planet and for human beings.

To Cuba, the content of this document is incompatible with the universally recognized scientific criterion which deems it urgent and unavoidable to ensure at least a 45% reduction of emissions by the year 2020, and no less that 80% or 90% by 2050.

This shameful document that you bring to us is also insufficient and ambiguous with regards to the specific commitment of the developed countries to reduce emissions even when they are responsible for the global warming resulting from the historic and current level of their emissions, and it is only fit that they undertake meaningful reductions right away.  This document fails to mention any commitment by the developed nations.

Confused ?   Depressed ??   Frustrated ???

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Some Observations from the 2009 UNFCCC Copenhagen Climate Summit:

1.  The 2009 Copenhagen Accord is a voluntary political agreement among a small number of countries … an arrangement of convenience.  It has no status within the international framework of the 1992 Convention on Climate Change and the 1997 Kyoto Protocol … it is a non-document.  It does, however, provide political cover for Brazil, South Africa, India and China (BASIC) … along with the USA … whose politicians have no wish to be bound by legally binding, meaningful GHG Emission Reduction Targets benchmarked back to 1990 levels … most especially, GHG Emission Reductions which would be stringently and independently verified by competent external agencies.  The Accord also has the potential, within it, to derail the entire UNFCCC process.

The Accord is not, therefore, being presented on this WebSite.

2.  The Developed Countries (i.e. the 1992 UNFCCC Annex I Countries) demonstrated that they had a small understanding of, but very little sympathy for, the concepts of ‘equity’, ‘fairness’, ‘historical responsibility’ and ‘climate justice’.

3.  It is now clear that the European Union’s Climate Change Targets of (i) a maximum 2 degree Celsius rise in global temperature is too high … a maximum 1.5 degree Celsius rise should be the target, with an essential reference to a ‘safety factor’ in all calculations … and (ii) a 20% Greenhouse Gas (GHG) Emission Reduction by 2020 is far too low.  The time for playing games with numbers is over … GHG Emission Reductions by the EU Member States should be open to stringent and independent/external verification … not just by the European Commission (which is insufficient, on its own, in this particular case) … but also by competent indigenous agencies in the BASIC Group of Countries.  To heal the rifts at Copenhagen … greater openness and transparency is required from Europe !!

Spinning of EU GHG Emission Reduction Performance by the European Environment Agency (EEA) … to make it appear that Europeans are doing more, and better, than we actually are … should be firmly knocked on the head, i.e. forbidden !

And in Ireland, to bring this subject closer to home, we urgently need to find another home … one central location, properly managed … for the relevant/related GHG Databases currently held by the Environmental Protection Agency (EPA) and Energy Ireland (SEI).  Here … let us recall a pertinent extract from the European Union Treaties … ‘statistics shall conform to impartiality, reliability, objectivity, scientific independence, cost-effectiveness and statistical confidentiality’.  This issue has been discussed in previous posts.  So … say no more !!!!

4.  Developed Countries continue to show a feigned interest in Climate Change Adaptation.  Too much of their energies and resources are still being directed at fully exploiting the ‘flexibilities’ in meeting Kyoto GHG Emission Reduction Targets.  They are wealthy enough … and they believe (mistakenly) that they possess all of the institutional capacities necessary to deal with any adverse impacts caused by Climate Change, including Variability and Extremes.  We have found recently in Ireland, however, during the National Major Flood and Snow Emergencies that we certainly do not have these capacities.  If anything, we now know that the relevant institutions in this country are incompetent, disorganized and dysfunctional.

Bearing in mind that the minimum life cycle for a Sustainable Building (just to take one important component of the Built Environment) is 100 years … the abject failure to reach a legally binding consensus agreement at Copenhagen … means that National Adaptation Strategies must now be planned and formulatedurgentlyon the basis of, at the very least, a 3-4 degree Celsius rise in global temperature.

What is Climate Change Adaptation ?

This encompasses, generally, all actions to reduce the vulnerability and strengthen the resilience of the Human Environment, including ecological and social systems, institutions and economic sectors … to present and future adverse effects of climate change and the impacts of response measure implementation … in order to minimize the threats to life, human health, livelihoods, food security, assets, amenities, ecosystems and sustainable development.

Built Environment Climate Change Adaptation, more specifically, means … reliably implementing policies, practices, projects and institutional reforms in the Built Environment … with the aim of reducing the adverse impacts and/or realizing the benefits directly/indirectly associated with climate change, including variability and extremes … in a manner which is compatible with Sustainable Human and Social Development.

Many opportunities can arise from Adaptation.

Why is a Sustainable Approach to Climate Change Adaptation Necessary ?

As an example and very briefly …

In Ireland, it has been proposed as an Adaptation Project … to divert water from the Shannon, a very large river in the west of the country … to Dublin, the capital city, which is located on the east coast … in order to deal with the expected shortage of water which will be caused by Climate Change in the medium term … among other factors.

“Fine”, you might say … and you may later add: “an interesting civil engineering infrastructural project”, as you visualize, in your mind’s eye, impressive Roman Aqueducts in the south of France or outside Rome.

BUT … if you then consider that there are no residential water charges in Dublin (so the concept of water conservation is almost unknown among householders); water supplied to houses in the Dublin Region are not yet metered (so there is no urgency to locate and deal with water leakage inside the private property boundary); there are enormous unintended losses, i.e. leaks, from the public potable water distribution system (approximately 40% even in the good times, and recently well in excess of 60% following the National Snow Emergency !); there are no requirements in our National Building Regulations to harvest any rainwater in any buildings or on any hard surfaces in the vicinity of those buildings … and, finally, Sustainability Impact Assessment (SIA) is not yet a standard procedure, at any level, within National and Local Authorities Having Jurisdiction.

So … just how ‘sustainable’, in reality, is the Shannon-Dublin Water Diversion Scheme as a Climate Change Adaptation Project ???

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Buildings of Historical, Architectural & Cultural Importance !

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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Note on BER Certificates for Historical Buildings in Ireland

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

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

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

 

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

 

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

 

 

 

The BER Gold Rush Soap Opera so far …

 

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

 

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

 

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

 

SEI’s Register of BER Assessors is unreliable.

 

What a magnificent waste of time, energy and money !

 

 

 

Some Comments on a Recent BER Certificate … 

 

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

 

This particular BER Certificate Documentation comprises:

 

         the actual BER Certificate ;

 

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

 

         its accompanying BER Advisory Report.

 

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

 

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

 

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

 

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

 

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

 

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

 

 

 

What’s Next ?

 

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

 

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

 

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

 

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

 

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

 

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

 

         increase accuracy ;

         reduce uncertainty ;

         improve reliability.

 

 

 

An Initial Proposal

 

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

 

 

1.  The BER Certificate

 

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

 

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

 

A BER Certificate should not be valid without this Appendix.

 

 

2.  The Accompanying BER Advisory Report

 

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

 

Include Additional Components in the BER Advisory Report:

 

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

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

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

 

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BER Certificates & ‘Big Brother’ – 1984 Style ? (V)

2009-04-14:  ‘Big Brother’ has arrived on our doorsteps … not in the style of today’s reality television … but in the George Orwell 1984 style of a generation ago … when 1984 used to be far into the distant future.

 

I wasn’t quite sure, but I thought that some readers … avid followers of Ireland’s BER Soap Opera … might be interested in the contents of a certain Important Notice Regarding BER Certificates (on official headed notepaper) … with the name of Mr. Steven Manek MIAVI, Partner, Douglas Newman Good (estate agents) at the bottom of the page … and dated March 2009 … which was circulated to DNG’s client vendors …

 

” We have now been advised by the Irish Auctioneers and Valuers Institute (IAVI) to contact all our vendor clients and advise them that an officer from one of the local authorities has started visiting estate agents’ offices in the greater Dublin area to inspect BER certificates for properties currently for sale/rent.

 

The IAVI have further advised us that if a certificate is not available the inspector is currently allowing a short grace period for provision of a certificate (even though there is no legal reason for them to do so).  If a certificate is not available within that time frame there is a risk of prosecution thereafter as it is a legal requirement to provide a BER certificate.  The maximum fine for a vendor under the legislation is €5,000.

 

In view of this we wish to formally notify you of your legal obligations and recommend that you obtain a BER certificate for your property as soon as possible.

 

The energy rating of a property must be carried out by a trained and registered SEI Building Energy Rating Assessor (BER Assessor).  We have a panel of assessors that can undertake this certification for you and should you wish us to handle this for you please do not hesitate to contact me.

 

 

Like too many other people … Steven does not seem to have taken the time to read the actual legislation.  Or, maybe he has … which is worse … whatever !

 

The clear intention of this nasty piece of DNG propaganda, however, is to scare the living daylights out of their own client vendors … and to drive them, like lost little sheep into the long spindly arms of their own in-house BER Assessors.

 

 

Hold onto your liathróidí folks !

 

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BER Certificates & Necessary Sectoral Infrastructure (IV)

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

 

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

 

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

 

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

 

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

 

 

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

 

 

1.  Construction Data & Statistics:

 

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

 

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

 

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

 

 

 

2.  A Concerted Programme of Infrastructure Restoration:

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

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

 

 

 

3.  Initial Construction Quality:

 

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

 

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

 

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

 

Foundations ;

Drainage ;

Ground Floor Construction ;

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

Roof.

 

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

 

 

 

4.  Consumer Protection:

 

         Establish an Independent and Comprehensive National Building Insurance Scheme.

 

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

 

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

 

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

 

         Introduce a Mandatory Building Completion Certification System.

 

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

 

Building Completion Documentation can be designed to include …

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

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

         a Building Energy Rating (BER) Label ;

         a Sustainability Impact Assessment (SIA) ;

         etc., etc.

 

 

 

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

 

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BER Certificates, Legislation & Thermal Comfort (I)

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

 

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

 

 

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

 

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

 

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

 

 

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

 

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

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

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

  

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

 

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

 

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

 

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

 

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

 

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

 

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

 

 

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

 

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

 

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

 

 

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

 

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

 

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

 

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Building Energy Rating (BER) Certificates – Worried ?

2008-12-12:  Thursday, 1 January 2009, is fast approaching, and any person offering an existing house for sale or rent around this time is being bombarded by all sorts of ‘marketing blurbs’ in the different media about having to produce a BER Certificate.

 

Don’t be worried.

 

When in doubt, go directly to the actual legislation … and in this case, it is Statutory Instrument No.666 of 2006: European Communities (Energy Performance of Buildings) Regulations 2006.

 

Legislation cannot be retrospective … so, if a house has already been offered for sale or rent before 1 January 2009, no BER Certificate is required.

 

 

BER Certificate Ireland

Colour image of an Irish BER Certificate. See S.I. No.666 of 2006: European Communities (Energy Performance of Buildings) Regulations. Click to enlarge.

 

And … if you care to look at the text on one of these ‘certificates’ (in the top right-hand corner), you will notice the following …

 

” The Building Energy Rating (BER) is an indication of the energy performance of this dwelling.”

 

However, unless long wave infra-red thermography has been used under proper conditions, by a competent person, as part of a comprehensive energy survey of the house … and thermal images were taken … and other accurate and precise information was gathered about the actual energy performance of this specific house … the statement in the BER Certificate is misleading.

 

There is only a very tenuous relationship between a BER Certificate and the ‘real’ energy performance of a specific building.

 

What’s more …. Energy Ireland (SEI) knows full well that this is the case.

 

 

In addition, as if that were not bad enough …. Energy Ireland (SEI) have been sitting on a Report for approximately 3 years which indicates that there is a general non-compliance rate of 70% (that’s right folks !) with the minimal – some might say “abysmal” – energy performance requirements, which apply to new houses, in Part L of the Irish Building Regulations.

 

And …. because everybody can see that our national system of building/technical control in Ireland is entirely inadequate, that figure of 70% non-compliance may be an underestimate.

 

Many, many months ago, I asked for a copy of this SEI Report.

 

I am still waiting.

 

 

[2009-01-12   Who did I ask ?   Mr. Brendan Halligan, SEI Board Chairperson & Mr. Kevin O’Rourke, SEI Head of Built Environment !]

 

.

 

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END

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