Ar C.J. Walsh Technical Blog – Registered Architect, Fire Engineer & Independent Technical/Building Controller …… International Expert on Accessibility (incl. Fire Safety & Evacuation) for ALL + 'Real' Sustainability Implementation ! …… NO ADS & NO AI HERE !!
2023-08-21: In an earlier Post here, dated 2022-12-19, I presented a Road Map for Sustainable Fire Engineering (#SFE) … which finished on an Urgent Call to Action targeting three specific, fundamental aspects of a Creative Fire Engineering which is capable of answering the challenges of our Complex Built Environment in the 21st Century … under severe threats from Global Climate Disruption, Climate Synergies leading to near-term Climate Tipping Points … and a startling lack of Global Resilience, refer to the CoVID-19 Pandemic, and Supply Chain Chaos initiated by an old-fashioned Cold War I Warrior in Washington’s White House.
Mainstreaming a Transformed Fire Engineering
Ethical Practice of Fire Research and Science
Reliability of Fire Statistics …
Colour Image showing the #SFE Road Map’s Conclusion, Page 31 in a series of 36, from the updated (June 2022) Presentation on Sustainable Fire Engineering ~ its essential and critical role in realizing a Safe, Resilient and Sustainable Built Environment For ALL. Click to enlarge.
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From Any Point Of View … the Final Report of ‘EU FIRESTAT’, a project financed by the European Parliament and commissioned by European Commission Directorate-General DG GROW, is a white elephant … a plodding hippopotamus … a retrograde step … a bitter disappointment !!! Completed in July 2022, it comes nowhere near outlining a viable system for the development of urgently needed Harmonized European Fire Statistics … which must be managed and co-ordinated by #Eurostat, in Luxembourg.
The #FIRESTAT Objectives were extremely limited …
‘ The review proceeds from the assumption that fire incident data can serve a number of important purposes – helping to reduce fires and losses, identifying opportunities for safety interventions and education programs, guiding the allocation of public resources to areas of greatest need and impact, and monitoring progress of safety initiatives.’
Nowhere, in this Report, is there any reference to Sustainable Human and Social Development. Where there are references to ‘sustainability’, these are specifically concerning the long-term financial resourcing of statistical systems.
And nowhere is there even the faintest understanding that Fire Engineering has an essential and critical role in the realization of a Safe, Resilient & Sustainable Built Environment For ALL. Fire Engineering Performance Indicators, Targets and Benchmarks must be developed to facilitate that realization ; and Reliable Fire Statistics are their starting point and basic ingredient.
The Report’s Executive Summary (in English, French, and German) covers the limited range of the Project pretty well … and it is almost easy to read. The ‘great and the good’ of Conventional Fire Engineering, both organizations and individuals, were involved in this Project …
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Colour Image showing the cover of the EU Project ‘FIRESTAT’ Final Report, completed in July 2022, with the full title of the Project: ‘EU FIRESTAT – Closing Data Gaps & Paving The Way For Pan-European Fire Safety Efforts’ in the middle of the Page ; the European Commission Logo at the top of the Page ; and against a background of an EU Flag in the lower half of the Page, the list of 9 International Fire Safety Organizations in the Consortium which carried out the Project. Click to enlarge.
The Final Report’s Boxed Recommendation 3, on Page 8, lists 8 Variables / Statistics to be collected as a Tier 1 / 1st Priority across Europe, from Ireland all the way down to Türkiye :
Number of Fatalities ;
Number of Injuries ;
Age of Fatalities ;
Primary Causal Factor ;
Type of Building ;
Incident Location ;
Incident Date ;
Incident Time.
So, for instance … the only Fire Statistic related to the Human Condition of Fatalities and Injured which would have been gathered after the 2017 Grenfell Tower Fire in #London was … Age of Fatalities … which, in the context of what actually happened on that tragic night and knowing the very large numbers of People with Activity Limitations (2001 WHO ICF) and other Vulnerable Building Users who died, or were injured, in the fire … is a very serious error, and entirely ridiculous !!??!! FUBAR !!
Essential Variable / Statistic Correction: Age, Gender and Vulnerability of Victims (whether Fatality or Injured). This is critical information and, whatever the resource implications, must be collected.
And if that wasn’t bad enough … this cack-handed approach to the development of Harmonized European Fire Statistics opens up the probability of another Morán with a computer, after a similar fire incident, again showing that a similar High-Rise Residential Tower could be evacuated down a single, narrow, badly designed staircase in 7 minutes. Say no more !!!
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J’Accuse / I Accuse the International Fire Engineering Community of being intentionally and maliciously Deaf, Dumb and Blind to the desperate Fire Safety Needs of People with Activity Limitations, including People with Disabilities, and other Vulnerable Building Users !
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Concerning Incident Date … the Consortium appears to be completely unaware that the European Standard Short Format Date is … Year-Month-Day (YYYY-MM-DD) !! See 4.2.2. in the Final Report. Sloppy, Sloppy, Sloppy.
Generally concerning Tier 1 Statistics … where is there any serious consideration of the deep and substantial Green / Environmental / Climate Disruption Mitigation and Adaptation Measures being imposed on the Design and Operation of New and Existing Buildings … which are already causing serious fire safety problems ??? See many previous Posts on this Technical Blog.
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Colour Image showing #IPCC AR6 Synthesis Report Figure 5a: ‘Limiting warming to 1.5 C and 2 C involves rapid, deep and in most cases immediate greenhouse gas emission reductions’ … from the Intergovernmental Panel on Climate Change 6th Assessment Report. Current emission reduction policies will result in global warming of approximately 3.2 C, which is far off target. Click to enlarge.
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The Final Report’s Boxed Recommendation 3, on Pages 8 & 9, goes on to list 6 Extra Variables / Statistics to be collected as a Tier 2 / 2nd Priority across Europe, from Portugal all the way up to Finland :
Number of Floors ;
Area of Origin ;
Heat Source ;
Item First Ignited ;
Articles Contributing to Fire Development ;
Fire Safety Measures Present.
Concerning Fire Safety Measures Present … my patience is at an end ! I am heartily sick and tired of pointing out that there is no such thing as a ‘Fire Door’ ; it does not exist !! It is ALWAYS a Fire Resisting Doorset !!! See 4.4.3.
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This EU ‘FIRESTAT’ Report properly belongs to the Twilight Zone of the last Century … and in today’s Recycling Bin !
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And Even More Worrying …
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Concerted Resistance to answering the Fire Safety Needs of Vulnerable Building Users ;
The mistaken view that ‘Sustainability’ is merely a graft-on / optional extra to Conventional Fire Engineering ;
Constraining Building Fire Safety Performance within the boundaries of Current Fire Codes ;
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Is the EU ‘FIRESTAT’ Final Report another disturbing sign of the growing Trend towards #GREENWASHING in International Fire Engineering ?
2013-04-02:Sustainable Design International Ltd. (SDI) is pleased to announce that its Managing Director, C.J. Walsh, has been invited to be ‘Project Design Architect’ / ‘Design Professional in Responsible Charge’ for aNew 32 Storey Hotel in Yunnan Province, People’s Republic of China (PRC).
He will have responsibility for the Project’s Architectural Concept Design and General Schematic Design … including the overall architectural character and profile of primary exterior surfaces.
Project Approximate Value = € 65 Million (Euros) … excluding interior design, finishes and furnishing (which could end up doubling, or even tripling, the overall project value).
Sustainable Design International Ltd. maintains a strict practice policy of Client Confidentiality.
[ If this Type of Professional Design Service Appeals to You, or Your Organization – Contact Us Immediately ! ]
An estimated One Billion People will be living in China’s cities by 2030. This large-scale and very rapid urbanization demands that a sustainable transformation of their urban built, social, economic and institutional environments commences Today – not at some notional point in a far distant future.
Furthermore … replicating a European approach to sustainable design and construction in other regions of the world is doomed to failure. Urban Transformation in China must be adapted to Local Geography, Climate, Climate Change, Social Needs, Cultures, Economy, and Local Severe Events (e.g. earthquakes, flooding). With European support and collaboration … China must, and will, find its own way.
Click the Link Above to read and/or download a PDF File (4.42 Mb)
Report on a One-Day China Advisory Council Roundtable, co-organized by Friends of Europe and EuroChambres, which was held in Brussels on 8 March 2012. This event was part of an ‘Understanding China’ Programme (mid-2009 to mid-2012), co-funded by the European Commission.
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2013 Asian Development Bank (ADB) Guidebook: ‘Increasing Climate Change Resilience of Urban Water Infrastructure’
This Guide describes a practical approach to bridge the gap between theoretical analyses of climate change impacts and the planning decisions that need to be made by city authorities and utility managers to increase climate change resilience of the water sector in the city of Wuhan, Hubei Province, People’s Republic of China (PRC). It focuses on answering the questions currently being asked by city planners and managers all over the world, as follows:
What changes might be caused by climate change ?
How will these changes affect services and utilities ?
What can we do now to prepare for them ?
The long lead time required to plan, finance, build, and commission city infrastructure facilities means that decision makers cannot wait for more detailed data on the effects of future climate change, especially those relating to local circumstances, but must make investment decisions based on what is known now and what can be readily predicted. An important principle in this kind of ‘robust’ decision-making is provided by the Intergovernmental Panel on Climate Change (IPCC) tenet that adaptation investments, which move a city’s infrastructure toward sustainable development (such as providing safe drinking water and better sanitary conditions), are justifiable even without climate change.
This Guide is arranged in clear steps to provide direction and information for similar exercises in other areas. Having grown out of a specific locality and its needs, the principles and solutions developed in this guide are founded on real world situations and problems …
Click the Link Above to read and/or download a PDF File (2.31 Mb)
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*** THIS TALL BUILDING IN YUNNAN PROVINCE & SIMILAR COMPLEX ARCHITECTURAL PROJECTS ***
Working within the professional constraints of ‘client confidentiality’ … it is possible to have a general discussion about current building design, construction and operation issues in an international sector which is operating, more and more, beyond national borders … without adequate, or very often any, national and local regulation. By ‘regulation’, I mean a flexible system of building-related legislation which is operated in conjunction with mandatory and effective technical control.
In order to cope with today’s complex built environment and the enormous variation in the size and scale of construction projects … a ‘flexible’ mix of functional, performance and prescriptive legal requirements is the sharpest and most appropriate instrument.
And you can forget the hype about performance-based building codes coming out of the USA … hot air, and much ado about little !
Of course, the biggest issue of all is the competence of those individuals who work in Authorities Having Jurisdiction (AHJ’s), i.e. technical controllers. Even in the most developed economies of the world … there are many occasions when the level of individual incompetence in an AHJ is astounding … and institutional arrangements within the AHJ itself are a mess, i.e. the AHJ is not fit for purpose.
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1. Sustainable Design – Design Process Efficiency & Proper Preparation for Construction
A tremendous amount of waste is associated with and generated by the processes of conventional building design, construction and operation. There is a more up-to-date and efficient way of doing things … an essential way for Sustainable Design … and it’s called Building Information Modelling (BIM) !
Furthermore … consider, for a moment, just the initial list of Specialist Consultants who will be engaged directly by the Chinese Client when the project’s conceptual design has reached a sufficiently developed stage. How can all of these individuals and organizations – listed in the revised and agreed Project Design Agreement – obtain accurate and reliable ‘real time’ information about the rapidly evolving project from a central design library / information database … then feed their new work back into the centre without unnecessary delay ? How, next, can everyone else who needs to know, be updated with the new design input … again, without delay ? And perhaps, these consultants may also be based in different countries … working in very different time zones …
Building Information Modelling (BIM) Consultant
Local Design Institute (LDI) … a local architectural practice which will produce the project’s working drawings, handle local spatial planning and building code approvals, carry out site inspections, and deal directly with construction organization(s), etc., etc.
Interior Design Consultant
Traffic / Parking Analysis Consultant
Curtain Wall Consultant (Curtain Wall, Skylights & Special Roof Structures)
Retail Market Analysis Consultant
Landscape Design Consultant
Quantity Surveying & Cost Estimating Consultant
Furniture Design Consultant
Geotechnical, Civil Engineering & Structural Engineering Consultant (including structural performance under fire and earthquake conditions, resistance to fire-induced progressive damage and disproportionate damage … and also including climate resilience)
Art, Artefact and Accessories Consultant & Procurement Services for Art, Artefacts, and Accessories
Tenant Storefront Design Consultant
Helicopter Landing Pad Design Consultant
Universal Design / Accessibility for All Consultant [including access to the building, electronic, information and communication technologies (EICT’s), and services offered at the hotel … and including fire safety, protection and evacuation for all]
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2. The ‘Design Professional in Responsible Charge’ !
The Project Design Agreement requests that the Client receive advice on who might be the different Specialist Consultants listed above. In addition, it will be necessary to demarcate the boundaries within which each Consultant will operate … and, where appropriate, to prescribe a design performance target (see below) for each speciality … which must be ‘realized’ in the completed and occupied building !
Recalling the many previous posts, here on this Technical Blog, concerning NIST’s 2005 & 2008 Recommendations on the 9-11 World Trade Centre Building Collapses in New York City … ‘somebody’ must ensure that the many individuals and organizations listed above – members of the Larger (2nd Stage) Design Team – use consistent design data and assumptions … must co-ordinate design documents and specifications to identify overlaps and eliminate gaps … must serve as ultimate liaison between the Client, the Local Design Institute, AHJ officials, and the Construction Organization(s) … and must ensure that everybody is on the same communication wavelength, and working towards the same objective in a trans-disciplinary manner.
That ‘Somebody’ … the Design Professional in Responsible Charge … must be the Project Design Architect !
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3. Some Sustainable Design Performance Targets
Actual construction and building user performance shall be carefully (i.e. reliably and precisely) monitored … and independently verified …
A.Basic Functional Requirements … the Building shall comply with the Basic Requirements for Construction Works – elaborated in Annex I of European Union (EU) Regulation No.305/2011 of the European Parliament and of the Council, of 9 March 2011, laying down Harmonized Conditions for the Marketing of Construction Products and Repealing Council Directive 89/106/EEC.
B.Good Indoor Air Quality (IAQ) … Two high-level performance indicators have been developed with the aim of protecting Human Health, and are both now referenced in International Standard ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’ …
– Radon Activity (incl. Rn-222, Rn-220, RnD) in a building should, on average, fall within the range of 10 Bq/m3 to 40 Bq/m3, but shall at no time exceed 60 Bq/m3 ;
– Carbon Dioxide (CO2) Concentrations in a building should not significantly exceed average external levels – typically within the range of 300 parts per million (ppm) to 500 ppm – and shall at no time exceed 800 ppm.
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C.Energy Conservation & Efficiency + A ‘Positive Energy’ Return + Assured Building User Thermal Comfort
2012-04-21: The context for considering and properly implementing Accessibility-for-All has changed … changed utterly … but some old problems persist, and stubbornly remain …
NEW INTERNATIONAL CONTEXT
A. At the time of writing, the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) has been ratified by 111 Countries and the European Union.
Concerning Accessibility of the Built Environment … UN CRPD Preamble Paragraph (g), and Articles 9 – 11 – 12 are the most immediately relevant. These texts can be easily found elsewhere on this BLOG … please use the ‘search’ facility at the top, right-hand corner of the WebPage.
With the innovative, and internationally accepted, understanding of ‘Accessibility’ – as distinct from ‘Access’ – contained in ISO 21542 : 2011 … the concept meaning: approach and entry to a building, circulation within and use of all the building’s facilities, egress from and removal from the building’s vicinity during normal circumstances, or evacuation in the event of an emergency and movement – via a safe and accessible route – to a place of safety which is remote from the building … it is now possible to deal with Fire Evacuation of Buildings through Article 9 (Accessibility) of the UN CRPD, where it is more in scale … more at home, so to speak … rather than through Article 11 (Situations of Risk & Humanitarian Emergencies), which had to be the case before.
B.ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’ … is the important new International Standard mentioned above. It was published in December 2011.
Ireland has no National Standard (or Code of Practice) on Accessibility. So, in the absence of an appropriate Harmonized European Standard, ISO 21542 must take precedence over the National Standards of any other European Union Member State.
Here, however, there is a very large fly in the ointment … the guidance text in the 2010 Technical Guidance Document M has been ‘lifted’, almost en masse, from a British National Standard on ‘Access’ … not ‘Accessibility’. And this flawed process has imported some serious errors into Irish Accessibility Design and Construction Practice … despite my warnings to the relevant authorities. Please refer back to this post , dated 2009-06-14.
Scope of ISO 21542 : 2011
ISO 21542:2011 specifies a range of requirements and recommendations for many of the elements of construction, assemblies, components and fittings which comprise the built environment. These requirements relate to the constructional aspects of access to buildings, to circulation within buildings, to egress from buildings in the normal course of events and evacuation in the event of an emergency. It also deals with aspects of accessibility management in buildings.
ISO 21542:2011 contains provisions with respect to features in the external environment directly concerned with access to a building or group of buildings from the edge of the relevant site boundary or between such groups of buildings within a common site. It does not deal with those elements of the external environment, such as public open spaces, whose function is self-contained and unrelated to the use of one specific building, nor does it deal with single family dwellings, other than those circulation spaces and fittings that are common to two or more such dwellings.
C. Of direct commercial interest within the European Union (and in any countries outside the EU who wish to trade with the EU and the European Economic Area) … Accessibility-Related Construction Products are now included in the framework of the (relatively) new European Union Regulation No.305/2011 of the European Parliament and of the Council, of 9 March 2011, laying down Harmonized Conditions for the Marketing of Construction Products and Repealing Council Directive 89/106/EEC. [The old EU Directive 89/106/EEC has been repealed … it is finished, it is gone, it is no more ! There will, however, be a suitable transition period from old to new.]
Construction Product (EU Reg.305/2011) means any product or kit which is produced and placed on the market for incorporation in a permanent manner in construction works or parts thereof and the performance of which has an effect on the performance of the construction works with respect to the basic requirements for construction works.
Construction Works (EU Reg.305/2011) means buildings and civil engineering works.
Basic Requirement for Construction Works No. 4 in Annex I of the new EU Regulation 305/2011, states the following …
Safety and Accessibility in Use
The construction works must be designed and built in such a way that they do not present unacceptable risks of accidents or damage in service or in operation such as slipping, falling, collision, burns, electrocution, injury from explosion and burglaries. In particular, construction works must be designed and built taking into consideration accessibility and use for disabled persons.
This is a suitable location for ‘Accessibility’ in Annex I … intimately connected to ‘Safety in Use’. However, there is one potential drawback. Specifying the level of safety in an EU Member State is the sole responsibility of the Authorities Having Jurisdiction (AHJ’s) in that Member State.
An Accessible Building is a Safer Building … but a Safe Building is not necessarily ‘Accessible’. ‘Accessibility’ is a completely different concept to ‘Safety’. EU Member States have no basis in EU Law … no justification whatever … for arbitrarily deciding on which level of ‘Accessibility’ is appropriate within their territories !
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SAME OLD PROBLEMS
With all of this New International Context on Accessibility finally in place … I continue to encounter the same old problems …
1.Bad Product Design
An enormous quantity of cheap, atrociously designed … you could almost use the word ‘ugly’ … Accessibility-Related Construction Products are imported every year into Ireland, from Britain. This is one good reason, although not a very satisfactory reason, why architects hate ‘accessibility’ in buildings. Building users notice fittings and fixtures … and if the fittings and fixtures are ugly … the building is ugly ! But occupational therapists, for example, are also specifying these types of products every day of the week here.
This has got to stop. Proper attention must be paid to Good Design of Accessibility-Related Construction Products. An Accessible Building does not have to look like a Hospital Ward ! And Good Design does not have to mean ‘expensive’ !!
I have seen many well designed Accessibility-Related Construction Products, available in the EU marketplace, which have been manufactured in countries such as France, Germany, Italy, and China.
Why can we not access these products in Ireland ??
2.No Product Approval
The National Building Regulations/Codes of EU Member States … and all EU Safety at Work legislation … demand that building products and systems must be properly shown to be ‘fit for their intended use in the location of use’. End of story … very simple ! Regrettably, few people take any notice of this legal requirement.
Late last year, however, I encountered a Chinese Company which manufactured some nicely designed Accessibility-Related Construction Products. I suggested to one of their sales personnel that, in order to place their products on the market anywhere in the European Union (or the European Economic Area) … there was an urgent need to update their existing ‘CE Mark’ Product Approval Documentation. When I checked more closely, this Documentation was dubious. I then suggested that they should place a correct, up-to-date and relevant CE Mark on their construction products … as a matter of priority. And I received the following reply …
” i’d like to suggest that maybe you can pay for the cost to do this CE, and after you place orders in our factory, we promise return that back to you, and if you like, maybe you can act as our agency in Ireland, will you ? “
[ The sum of money being discussed here was €1,000.]
This proposal was off-the-wall, as we say here in Ireland. But, I found it impossible to get annoyed … because this strange and weird understanding of the CE Mark, particularly in relation to Accessibility-Related Construction Products, is rife among European Manufacturers also … and European Notified Bodies. How crazy is that ?
Perhaps my most unusual experience, back in the mid-1990’s, was having to explain to a Manager in a TÜV Laboratory, in Germany, that a Full Test Report must be issued to a Test Sponsor … after the test(s) has/have been completed. This task required two to three hours of heated discussion !
And … in the absence of any reference to ‘Accessibility’ in the now repealed EU Directive 89/106/EEC … I have encountered some European Manufacturers of Accessibility-Related Construction Products … who, being fully aware of the value of a CE Mark, have used the backdoor method of the EU Medical Devices Directive in order to obtain a CE Mark. And these were definitely not medical devices !
There is no effective control over the CE Marking of Construction Products within the European Union. This is no reason to ignore the system … or to abuse the system.
However … if many more people paid attention to the legal requirement, and necessity, of Proper Product Approval and the CE Marking of Accessibility-Related Construction Products … and the professional duty and responsibility to check that compliance/conformity is properly shown … we would have a more Accessible and much Safer Built Environment !!!
2011-07-15: The recent failure by European Union Environment Ministers to increase, unconditionally, the EU 2020 GHG Emission Reduction Target from 20% below 1990 levels to 30% … and the even more recent vote in the European Parliament against such an unconditional increase … leaves a stench in the nostrils. Something stinks … and it’s the EU’s Climate Change Policy. Too many alterations to the European Lifestyle … too many sacrifices … are required to effectively implement a ‘real’ climate change policy !
Taken as a whole … this is also a reliable indicator with regard to what is not happening in a strongly related policy area … the implementation of EU Sustainability Policy.
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The next BIG United Nations International Climate Change Conference in 2011 – COP 17 – will take place from 28 November to 9 December, 2011 … in Durban, South Africa. Let’s not get our hopes up for the long-awaited, very necessary and urgent Global, Legally Binding Consensus Agreement on Climate Change Mitigation to be finalized there … but let’s not be too negative either !
And how are the UNFCCC Annex I Countries doing so far ? For an answer, please follow the link below to the United Nations Framework Convention on Climate Change (UNFCCC) WebSite …
I wrote ‘an answer’ … as this is not ‘the answer’ … because the Climate Change Numbers produced by each country are not yet sufficiently accurate, precise and reliable. In fact, there is so much massaging of numbers that it might be better just to imagine this whole process as the Climate Change Red Light District !
BUT … we do know enough to be able to identify the worst offenders:
34 – IRELAND !
35 – Iceland
36 – Greece
37 – Portugal
38 – New Zealand
39 – Spain
40 – Canada
41 – Australia
42 – Malta
43 – Turkey
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Looking back to when the Climate Change ‘Train’ began to come off the rails … the 2009 Copenhagen Accord was a political agreement between a small number of Heads of State, Heads of Government, Ministers, and Heads of Delegation from Brazil, South Africa, India and China (BASIC) and the USA … who attended the UNFCCC Climate Change Summit in December 2009. Many countries have made voluntary submissions, i.e. not legally binding, to Appendices I and II of the Accord.
A general overview of the submissions made by the Developed Economies, however, reveals the following about the emissions targets being undertaken …
– they are highly conditional on the performance of other countries ;
– they are very disappointing … being far below what is required to cap the planetary temperature rise at 1.5 degrees Celsius ; and
– there is no consistent emission base year … varying, for example, from 1990, 1992, 2000 to 2005.
This is very far from being a signal of serious intent from these countries … and is not … in any way, shape or manner … an acceptance of historical responsibilities. It would be reasonable, therefore, to surmise that the process of achieving a global, legally binding, consensus agreement on greenhouse gas (GHG) emission reduction targets will be long and difficult. The Climate Change Mitigation Agenda is fraught with difficulty … and is going absolutely nowhere at present !
Some Conclusions about Copenhagen and Since:
The Danish Organizers were entirely responsible for the 2009 Climate Change Train Wreck ! And … this incompetent bungling continues to contaminate events since then.
All Sectors of Europe’s Social Environment must now take seriously, i.e. pro-actively engage with, the Climate Change Adaptation Agenda … and prepare for a planetary temperature rise of at least 3-4 degrees Celsius before the end of this century !!
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Meanwhile, at national level in Ireland … and further to my post, dated 23 February 2011… the Environmental Protection Agency (EPA) issued the following Press Release on 4 July 2011 …
‘ Kerdiffstown Landfill Remediation Project – Community Update Number No. 4
Gas flares at the Kerdiffstown Landfill are now installed and fully operational. The flares burn off odorous gas that is collected by gas wells in two areas at the site – the lined landfill cell, and the North-West corner.
The lined landfill cell has now been fully covered with a heavy plastic membrane that will prevent gas escaping into the air. This membrane will also stop rainwater getting into the waste and creating ‘leachate’ – the residual liquid that seeps through waste after rainfall.
These temporary gas control measures should result in a reduction in odour coming from the site. Odour will continue to be encountered on occasion until the full remediation is completed and, in particular, there is a risk of odour during work phases where wastes will be disturbed.
The next major remedial works to occur on site will be the demolition of a number of unsafe buildings. The buildings are scheduled to be demolished in August, and the EPA will communicate the specific dates before the works commence.
On Friday, 1 July 2011, the EPA welcomed a number of TDs, councillors, council officials and members of the local community to the site for a briefing, and tour of the site works done to date. The EPA would like to thank deputies Emmet Stagg, Anthony Lawlor, and Catherine Murphy, and Councillors Anne Breen, Emer McDaid, and Ger Dunne, for attending.
The EPA then met with members of the Local Community for the first Community Liaison Group meeting. This group was formed to ensure that those people affected by the site can communicate directly with the people who will clean the site. The Liaison Group includes EPA staff, Kildare County Council officials, members of CAN (Clean Air Naas), a representative from Kerdiffstown House, and local residents and business people. The group took a tour of the site to review ongoing remedial works.
The EPA will continue to issue Community Updates as remedial works on the site take place. For information about works at the site, go to … www.kerdiffstowncleanup.ie .’
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Please read, again, that first paragraph of the Press Release above … and pinch yourself !
Ireland’s EPA has an onerous legal responsibility with regard to the development and implementation of this country’s National Climate Change Policy. Furthermore … the EPA, on its own WebSite ( http://www.epa.ie/ ) states the following …
‘ The Environmental Protection Agency (EPA) aims to be a leader in the climate change debate in Ireland, and to be the first port of call for information on climate change. We hope that the information we provide on these WebPages will keep you informed on the latest news, research and events in the climate change area, not only in Ireland but internationally.’
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I ask: “Why are those Landfill Gases at Kerdiffstown being burned off ???”
Because Ireland’s National Climate Change Policy is a ‘paper’ policy … an ‘Alice in Wonderland’ policy … a policy not intended for ‘real’ implementation. Surely we have a right to expect that, within the same national organization … somebody, somewhere … is able to think laterally ?
Climate Change Time is running out … and there is an immediate and desperate need for simple, direct and honest talk, consultation, awareness raising, training and education … across all sectors of our Social Environment !
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At European level … an example, to follow below, of the continuing weak and feeble Climate Change Language still being used by EU Institutions and Official Organizations … where individual employees, of all ranks, are more fearful of offending national and/or EU politicians than they are in doing their jobs properly and protecting EU Citizens and the Environment …
A recently published European Environment Agency (EEA) Technical Report 7: ‘Safe Water & Healthy Water Services in a Changing Environment’ … summarises existing knowledge of Climate Change Impacts on water services and health; the nature and effectiveness of the policy responses; and the coverage and gaps in existing assessments of these themes.
• Millennium Development Goal 7 (MDG7) is to halve the proportion of the global population without sustainable access to safe drinking water and basic sanitation by 2015. A World Health Organization (WHO) assessment in 2010 finds that access to improved water sources, sanitation and wastewater treatment has increased over the past two decades. In many countries in the Eastern European Region, however, progress is slow. More than 50% of the rural population in ten countries have no access to improved water, giving rise to important health inequalities.
• It is important to understand how Climate Change and Extreme Weather Events will affect the achievement of MDG7. Drinking water supplies and sanitation systems will have to be made resilient to Climate Change, and drinking water and sanitation must be fully incorporated into integrated water resource management.
• Climate Change is projected to cause major changes in yearly and seasonal precipitation and water flow, flooding and coastal erosion risks, water quality, and the distribution of species and ecosystems.
• Climate Change will impact all areas of water services – the quality and availability of water sources, infrastructure, and the type of treatment needed to meet quality standards. We will also see more frequent and severe droughts, flooding and weather events.
• Countries of Eastern Europe, the Caucasus and Central Asia face the greatest threats to safe water. The infrastructure in many towns and rural areas is in poor condition, and water provision is erratic and of unsatisfactory quality.
• Heavy rainfall events may also lead to flooding, especially in urban areas, and this can have serious impacts on the performance and efficiency of water supply and wastewater treatment systems, which may potentially lead to health risks. Waterborne diseases arise predominantly from contamination of water supplies after heavy rainfall and flooding.
• Low river flows and increased temperatures during droughts reduce dilution of wastewater effluent, and drinking water quality could be compromised, increasing the need for extra treatment of both effluent and water supplies.
Water Management Policies & Extreme Weather Events
• Water management policies at European and EU Levels are being made increasingly adaptable to Climate Change, which should help safeguard public health and ecosystem services in the future.
• There are numerous guidelines for the design of water and human health policies across Europe (e.g. WHO Guidelines on drinking water quality, Protocol on Water and Health, and draft guidance on water supply and sanitation in extreme weather). Recently, such Guidance has focused on how policy design and implementation might be affected by and adapted to Climate Change Events.
• The WHO Vision 2030 Study assesses how and where Climate Change will affect drinking water and sanitation in the medium term, and what can be done to maximise the resilience of drinking water and sanitation systems.
• Several existing EU Policies address water management issues (the Urban Wastewater Treatment Directive, the Water Framework Directive, Floods Directive and the EU Water Scarcity and Droughts Strategy) and others deal more directly with potential water-related impacts on human health (e.g. the Drinking Water Directive, and Bathing Water Directive).
• There is a clear recognition that Climate Change creates a need for coherent, sustainable, cross-sectoral policy and regulation; sharing of available tools; facilitating mechanisms for partnerships and financing; and readiness to optimise across sectors during implementation.
• The water utility sector faces a unique set of challenges. A primary challenge will be enhancing its capacity to cope with Climate Change Impacts and Other Human Pressures on water systems, while fostering greater resiliency to extreme hydrological events.
• With more frequent higher-intensity storms projected, utilities face the need to update infrastructure design practices. This necessitates investments – not necessarily only in larger structures but also smarter (using better process control technologies) or local measures on storm water run-off.
Assessment Knowledge Base
• At international, national and local levels … much information is produced for assessments of the state of water and related health impacts. Overall, both the current international and national water and health assessments have limited focus on extreme weather events and their effects on water services.
• In national assessments and programmes, countries appear to be aware of the adverse consequences of Climate Change on water and health. However, sometimes assessments appear to be based on ‘expert knowledge’, largely qualitative in scope, and not going further than identifying likely scenarios. The evidence‑base is lacking to make reliable estimates of the health effects of Climate Change resulting from impacts on water resources.
• Much effort is now focused on the impact of Climate Change on water and the environment, including health-related impacts. Many international and European organisations have mapped out future Climate Change Impacts on water-related issues, identifying vulnerable groups and vulnerable sub-regions.
• The vast majority of the assessments of drought and water scarcity have focused on the impact of water scarcity, water use by sectors and strategies for meeting demand. Very little consideration has been given to the health effects or consequences of future extreme weather events.
• The health effects of flooding do not feature significantly in national assessments. The main focus is identifying regions most at risk of flooding and preparing plans for responding and mitigating the main consequences.
• Sufficient public health competences exist to cope with the health effects of Climate Change. However, no (comprehensive) assessment has been undertaken to predict the severity or extent of future health risks related to the impact of Climate Change on water services.
• Irrespective of an assessment of the disease burden, actions being taken on the wider scale to respond to water scarcity, drought and flooding will help to reduce the health effects associated with Climate Change and water.’
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If you were a Key Decision-Maker … would this language spur you into action … or make you yawn, and put you to sleep ???
2010-12-22:November & December 2010 … when the shit really started to hit the international economic fan ! … there has been an excess of hysterical nonsense in the Irish Media concerning growing European Union (EU) Economic Governance … and a perceived erosion of Irish National Sovereignty. How sad ?!?
Economic Environment … the intricate web of real and virtual human commercial activity – operating at micro and macro-economic levels – which facilitates, supports, but sometimes hampers or disrupts, human interaction in the Social Environment.
Social Environment … the complex network of real and virtual human interaction – at a communal or larger group level – which operates for reasons of tradition, culture, business, pleasure, information exchange, institutional organization, legal procedure, governance, human betterment, social progress and spiritual enlightenment, etc.
However, let me sketch out an altogether different and much more positive picture !
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Thesis – My Argument
[During 2009, I first raised this issue in meetings of the IIEA (Institute of International & European Affairs) Economists’ Group, in Dublin.]
Towards the end of 2010 … we can now see that Inter-Governmental Economic Governance in the European Union has failed … miserably. This has not only destabilized the EuroZone … but the entire European Union, itself, as a political entity … and will continue to do so … until Economic Governance is brought much closer to, and fully within, the Community Method … which is a lengthy and complex process.
Back in 2009, however, when the Financial Markets were not in such a mad frenzy … it would have been natural to imagine that an interim stage in this process would most probably be to adopt an Open Method of Co-Ordination. This is no longer an option … being too little, too late, to calm the Markets.
Throughout this process of reform, the European Central Bank (ECB) and the National Central Banks can, and must, retain their independence … as legally mandated in European Union Primary Legislation, i.e. the Treaties.
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Three Concerns I have had for some time …
– Economists don’t know the Community Method from the Rhythm Method, and they are ill-equipped to deal with matters of Mainstream European Union Institutional Reform ;
– The use of Economic Performance Indicators in the EU Stability & Growth Pact is simplistic and crude … and, therefore, very problematic ;
– Economic Performance Indicators must be improved … qualitatively … and be mainstreamed in considerations, and the implementation, of Sustainable Human & Social Development … as legally mandated in the EU Treaties.
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Mr. Olli Rehn, European Commissioner for Economic & Monetary Affairs recently delivered a speech at the Institute of International & European Affairs, in Dublin …
Click the Link Above to read and/or download PDF File (39kb)
However … instead of trying to desperately backfill the holes and gaps in the current, failed Inter-Governmental Method of Economic Governance in the European Union … Commissioner Rehn should be clearly identifying the proper target as the Community Method of Economic Governance … and plotting an appropriate course to reach that target … as soon as practicable !
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This is a useful background document … and includes a lot of information about the EU Stability & Growth Pact …
European Commission & General Secretariat of the EU Council
Click the Link Above to read and/or download PDF File (2.66 Mb)
Since Ireland joined the European Economic Community (EEC) in 1973 … after 10 years of accession negotiations ! … an ‘informed’ view of European Integration has always been that the different Countries are pooling their national sovereignty, in an expanding range of specific areas, for the greater benefit of all their citizens. This has certainly been the experience of Ireland. And … let us also not forget that Irish Politicians and Senior Civil Servants have participated directly – at all stages – in the development of the EMU Legal & Political Texts listed. There is no such thing as a Domineering ‘Brussels’ Big Brother !
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This is the most recent update of the EuroZone’s Economic Performance Indicators …
European Commission, Directorate-General for Economic & Financial Affairs (DG ECFIN)
Click the Link Above to read and/or download PDF File (360kb)
It is now widely acknowledged that Gross Domestic Product (GDP) is neither a reliable nor an adequate indicator of Sustainable Human & Social Development. But … that is another story … for another day !
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Community & Inter-Governmental Methods of Governance
The Community Method is the expression used for the most common and effective operating and decision-making mode of institutions in the European Union. It proceeds from an integration logic, with due respect for the subsidiarity principle … and has the following salient features:
European Commission monopoly of the Right of Initiative, with a strong monitoring role in implementation ;
should consensus not be achieved, widespread use of Qualified Majority Voting in the Council of the European Union ;
an active, participatory role for the European Parliament ;
uniform interpretation of EU Law by the Court of Justice.
In contrast to the … Inter-Governmental Method … which proceeds from an inter-governmental logic of co-operation between EU Member States … to a large extent outside the institutional framework of the European Union … and has the following salient features:
the European Commission’s Right of Initiative is shared with the Member States or confined to specific areas of activity … with little, if any, monitoring role for the Commission in implementation ;
the Council of the European Union generally acts unanimously … and unilaterally ;
the European Parliament has merely a consultative role ;
the Court of Justice plays only a minor role.
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Open Method of Co-Ordination
The Open Method of Co-Ordination (OMC) developed as an instrument of the 2000 Lisbon Strategy, and provided a new framework for co-operation between the EU Member States, whose national policies could thus be directed towards certain common objectives.
Under this method of governance, the Member States are evaluated by one another (peer pressure), with the European Commission’s role being limited to ‘lite’ surveillance. The European Parliament and the Court of Justice play virtually no part in the OMC process.
The Open Method of Co-Ordination takes place in policy areas which fall within the competence of the Member States … such as employment, social protection, social inclusion, education, youth and training.
It is based principally on:
jointly identifying and defining objectives to be achieved (adopted by the Council of the European Union) ;
jointly established measuring instruments (statistics, indicators, guidelines) ;
benchmarking, i.e. comparison of the Member States’ performance and exchange of best practices (oversight by the European Commission).
Depending on the areas concerned, the OMC involves so-called ‘Soft Law’ Measures which are binding on the Member States to varying degrees but which never take the form of ‘Hard Law’ Directives, Regulations or Decisions. Thus, in the context of the Lisbon Strategy, the OMC required the Member States to draw up national reform plans and to submit them to the European Commission.
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Colour photograph showing the last resting place, in Arbour Hill Cemetery Dublin, for many – not all – Executed Leaders of the 1916 Revolution. The Memorial was designed by G. McNicholl. Photograph taken by CJ Walsh. 2010-10-24. Click to enlarge.
Ireland’s National Sovereignty in 2010/2011 ?
On a beautiful sunny day, this past autumn … I again visited Arbour Hill Cemetery in Dublin … the last resting place for many Executed Leaders of the 1916 Revolution … an event which finally initiated an irrevocable process of terminating a prolonged period of barbaric external imperial domination and cultural cleansing of the indigenous population …
Colour photograph showing, in the background, a latin cross and the Irish language version of the 1916 Proclamation of Independence inscribed on the stone wall, with the simple grass-covered graves of Executed Leaders in the foreground. Detail of the 1916 Revolution Memorial in Arbour Hill Cemetery, Dublin. Photograph taken by CJ Walsh. 2010-10-24. Click to enlarge.
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On the wall behind the graves … the 1916 Proclamation of Independence is inscribed in the Irish Language, and also in English …
Poblacht na hEíreann
THE PROVISIONAL GOVERNMENT OF THE IRISH REPUBLIC
TO THE PEOPLE OF IRELAND
IRISHMEN AND IRISHWOMEN: In the name of God and of the dead generations from which she receives her old tradition of nationhood, Ireland, through us, summons her children to her flag and strikes for her freedom.
Having organized and trained her manhood through her secret revolutionary organization, the Irish Republican Brotherhood, and through her open military organizations, the Irish Volunteers and the Irish Citizen Army, having patiently perfected her discipline, having resolutely waited for the right moment to reveal itself, she now seizes that moment, and, supported by her exiled children in America and by gallant allies in Europe, but relying in the first on her own strength, she strikes in full confidence of victory.
We declare the right of the people of Ireland to the ownership of Ireland, and to the unfettered control of Irish destinies, to be sovereign and indefeasible. The long usurpation of that right by a foreign people and government has not extinguished the right, nor can it ever be extinguished except by the destruction of the Irish people. In every generation the Irish people have asserted their right to national freedom and sovereignty: six times during the past three hundred years they have asserted it in arms. Standing on that fundamental right and again asserting it in arms in the face of the world, we hereby proclaim the Irish Republic as a Sovereign Independent State, and we pledge our lives and the lives of our comrades-in-arms to the cause of its freedom, of its welfare, and of its exaltation among the nations.
The Irish Republic is entitled to, and hereby claims, the allegiance of every Irishman and Irishwoman. The Republic guarantees religious and civil liberty, equal rights and equal opportunities to all its citizens, and declares its resolve to pursue the happiness and prosperity of the whole nation and of all its parts, cherishing all the children of the nation equally, and oblivious of the differences carefully fostered by an alien government, which have divided a minority from the majority in the past.
Until our arms have brought the opportune moment for the establishment of a permanent National Government, representative of the whole people of Ireland and elected by the suffrages of all her men and women, the Provisional Government, hereby constituted, will administer the civil and military affairs of the Republic in trust for the people.
We place the cause of the Irish Republic under the protection of the Most High God, Whose blessing we invoke upon our arms, and we pray that no one who serves that cause will dishonour it by cowardice, inhumanity, or rapine. In this supreme hour the Irish nation must, by its valour and discipline and by the readiness of its children to sacrifice themselves for the common good, prove itself worthy of the august destiny to which it is called.
Signed on Behalf of the Provisional Government,
THOMAS J. CLARKE,
SEAN Mac DIARMADA, THOMAS Mac DONAGH,
P. H. PEARSE, EAMONN CEANNT,
JAMES CONNOLLY, JOSEPH PLUNKETT.
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As We Approach the 100th Anniversary of the 1916 Revolution …Ireland has failed to implement and foster the social values so eloquently elaborated in the 1916 Proclamation of Independence … widespread, deeply ingrained corruption infects our economic environment … and the institutions of national governance are dysfunctional and no longer ‘fit for purpose’ … while individuals within those institutions rise in rank according to their own natural level of incompetence.
Politically … Ireland has not yet properly matured as an Independent State.
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Ireland’s Relationship with the European Union … I am more than a little curious as to why Ireland is not associated with Declaration No.52, which is annexed to the Treaty of Lisbon …
52. Declaration by the Kingdom of Belgium, the Republic of Bulgaria, the Federal Republic of Germany, the Hellenic Republic, the Kingdom of Spain, the Italian Republic, the Republic of Cyprus, the Republic of Lithuania, the Grand-Duchy of Luxembourg, the Republic of Hungary, the Republic of Malta, the Republic of Austria, the Portuguese Republic, Romania, the Republic of Slovenia and the Slovak Republic on the symbols of the European Union
Belgium, Bulgaria, Germany, Greece, Spain, Italy, Cyprus, Lithuania, Luxemburg, Hungary, Malta, Austria, Portugal, Romania, Slovenia and the Slovak Republic declare that the flag with a circle of twelve golden stars on a blue background, the anthem based on the ‘Ode to Joy’ from the Ninth Symphony by Ludwig van Beethoven, the motto ‘United in diversity’, the euro as the currency of the European Union and Europe Day on 9 May will for them continue as symbols to express the sense of community of the people in the European Union and their allegiance to it.
Yes … we have a lot to discuss before 2016 !
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Update: 2013-06-03 …
On Friday, 31 May 2013, at the Institute of International & European Affairs (IIEA) in Dublin … I attended the third seminar in a series organized to mark Ireland’s Presidency of the Council of the European Union (January to June 2013) … the seventh such Presidency … and 40 years since Ireland officially joined the European Economic Community (EEC), on 1 January 1973 … after a long, long, long accession process …
‘Economic Sovereignty in an Age of Globalization and EU Integration – Economic, Legal and Political Perspectives’
[ For full information about this IIEA Economic Seminar: www.iiea.com ]
Because the seminar was not only very interesting, but is directly relevant in the context of this post … and the remarks of Mr. Peter Sutherland, Chairman of Goldman Sachs International and the London School of Economics, and former Irish Attorney General, former European Commissioner and former Director-General of the World Trade Organization, caused quite a stir in the printed media on the following day … here is Paper 2 from Seminar Session I … which went to the heart of discussions on the day …
Prof. John W O’Hagan, Dept. of Economics, Trinity College Dublin, Ireland
Click the Link Above to read and/or download PDF File (635 Kb)
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Update: 2014-07-04 …
Economists exist and operate in a special bubble … in their own little isolated world of quasi-science and fantasy, where everything in ‘our’ society is seen merely as an input, or fuel, for economic development. And when they talk about Sustainable Economic Growth … believe me, their notion of ‘sustainable’ is altogether different from our understanding of that word !
It should come as no surprise to learn, therefore, that economists are blissfully unaware that the EuroZone’s current directionless (and dysfunctional) economic governance is causing enormous instability and harm to the whole political entity that is the European Union …
Flow chart diagram, in colour, showing how it is proposed that The European Semester will operate … which EU Institution will do what, and at what stage every year. Source: Council of the European Union. Click to enlarge.
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This issue is too important for all of us … to be left to economists and national politicians, alone, to muddle through !
2009-02-27: Energy Labelling of Industrial Products is an essential means of raising consumer awareness about energy efficiency and conservation.I like being able to wander into an electrical shop anywhere in Ireland, Italy or Turkey, for example … and to compare the energy performance of different makes of washing machines, dishwashers or fridges … and even of apparently similar products in the different countries.
I can easily visualize these small industrial products being brought into a test laboratory, and then being put through their paces.It is a credible system.
This is NOT possible, however, with a building.
EU Directive 2002/91/EC of the European Parliament and of the Council, of 16 December 2002, on the Energy Performance of Buildings … is a short document of 7 Pages.Its Preamble takes up slightly more than the first 2 Pages, and there is a 1 Page Annex at the rear.Its language is clear and straightforward (see the example of Article 4 below).
[What I fail to understand is how and why the Irish National Legislation which implements the Directive … Statutory Instrument No. 666 of 2006: European Communities (Energy Performance of Buildings) Regulations 2006 … is so clumsy, awkward and full of flaws … offering us yet another example of failed ‘light-touch regulation’.It may also be unconstitutional.]
The EU Directive has something important to say about Indoor Air Quality …
Article 4 – Setting of Energy Performance Requirements
1. Member States shall take the necessary measures to ensure that minimum energy performance requirements for buildings are set, based on the methodology referred to in Article 3.When setting requirements, Member States may differentiate between new and existing buildings and different categories of buildings.These requirements shall take account of general indoor climate conditions, in order to avoid possible negative effects such as inadequate ventilation, as well as local conditions and the designated function and the age of the building.
[Quick flashback to a generation ago … the panic, throughout Europe, to conserve energy in the late 1970’s and early 1980’s led to a dramatic reduction in rates and quantities of direct, natural ventilation to the habitable spaces of buildings.This, in turn, had an adverse impact on Indoor Air Quality, and led to a sharp rise in Asthma among building occupants.]
In Ireland, today, problems concerning Poor Indoor Air Quality continue to occur … typically during the Winter Heating Season.There is a natural tendency to keep windows closed and to seal permanent ventilation openings. Accidental indoor air seepage to the exterior is also being reduced in our newer building stock.
Poor Indoor Air Quality, an important factor in relation to building related ill-health (also known as ‘sick building syndrome’), can cause serious health impairments and severely restrict a person’s participation in everyday activities, e.g. work.
Symptoms and Signs may include:
–irritation of eyes, nose and throat ;
–respiratory infections and cough ;
–voice hoarseness and wheezing ;
–asthma ;
–dry mucous membrane and skin ;
–erythema (reddening or inflammation of the skin) ;
–lethargy ;
–mental fatigue and poor concentration ;
–headache ;
–stress ;
–hypersensitivity reactions, i.e. allergies ;
–nausea and dizziness ;
–cancers.
The following 2 Performance Indicators of Good Indoor Air Quality, developed with the aim of protecting human health, are recommended:
–Carbon Dioxide (CO2) concentrations in a building should not significantly exceed average external levels – typically within the range of 300 to 500 parts per million – but should at no time exceed 800 parts per million ;
–Radon Activity (including Rn-222, Rn-220, RnD) in a building should, on average, fall within the range of 10 to 40 Bq/m3 … but should at no time exceed 60 Bq/m3.
NOTES:
The concept of Protecting Human Health is altogether different from the concept of Assessing Risk to Safety.
In Ireland, testing for Radon Activity in buildings must take place during the Heating Season, i.e. the months of November through to March.What is the use of testing during July, for example, when windows will be wide open ? Who would even think of doing that ?I wonder.
Measurement Uncertainty of the standard Alpha Particle Etched-Track Detector distributed by the Radiological Protection Institute of Ireland (RPII) is as follows:
–under laboratory conditions: …………………… in the order of …… +/- 10%
–under tightly controlled site conditions: …. in the order of …… +/- 20%
–under typical conditions of use: …………….. well in excess of … +/- 30%
Unfortunately, until the RPII includes proper statements of Measurement Uncertainty in its Test Reports … our Organization cannot recommend RPII Radon Testing Services, and we will not accept RPII Test Reports as proper evidence of Radon Test Results.
