Irish National Legislation

Sustainable Buildings – Design Agenda for the 21st Century ?

2009-05-06:  From the late 1980’s and the beginning of the 1990’s in European Union (EU) Research Programmes, it was noticeable that the more pressing early concerns about Energy-efficiency – logical after the oil crises of the 1970’s – were beginning to merge with those of Environment-friendliness, i.e. protection of the environment.  Even at that time, however, faint background references to Sustainability were becoming more common.

 

In 1995, therefore, Sustainable Design International developed and introduced the acronym ‘SEED’ … which stands for Sustainable, Environment-friendly, Energy-efficient Development … as a practical control, or check, on our own work output.

 

 

The next break-through came a few years later.  I briefly discussed the wide conceptual basis for our Corporate Design Philosophy in the post: ‘Sustainable Human & Social Development ?’, dated 2009-03-31.  This basis, while still continually evolving, is critical in terms of services provided, performance targets to be achieved, methods of working and relationships with client organizations, builders, craftsmen/women, manufacturers, etc.

 

This should explain the futility, in our humble view, of the ‘Green’ Agenda (as distinct from the ‘Sustainability’ Agenda) … and approaches based solely on Environmental Aspects of Sustainable Development.  They are a complete waste of time and resources.

 

 

Now in 2009, we remain fully convinced that Sustainable Design Solutions are appropriate to local geography, social need, climate, economy and culture … and are ‘person-centred’ and ‘reliability-based’.

 

Forget the images of mud housing and reading by candle light … the Future of our Built Environment is High-Tech, Smart … and Sustainable !   Let there be no doubt !!

 

 

 

Why not begin, so, by looking at a Simple Building Type … Sustainable Housing ?

 

With all of the current hype and fuss about German ‘Passiv’ Houses and Austrian High-Tech Timber Framed Construction … we have been in contact with a number of manufacturers in this region of Central Europe.  After many meetings and detailed discussions, we are disappointed … broken hearted !

 

Below follows our shopping list for the practical, commercial and affordable application, i.e. non-research, of Advanced Systems of Construction (small/medium/large scale projects – new-build and existing projects).

 

N.B.  Current Irish legal requirements and local authority technical control procedures are entirely inadequate.

 

Is anybody out there listening ???

 

 

 

To meet the urgency of Climate Change Adaptation and the challenge of Reliable Sustainability Implementation … a ‘SEED’ Building in Ireland must reach these performance targets:

 

         be set in Sustainable Landscaping (where appropriate) with Life Cycle Sustainable Drainage … and exhibit a considered, harmonious relationship between the building’s ‘interior’ environment and the ‘exterior’ built and social environments ;

 

         have a Minimum Building Life Cycle of 100 Years ;

 

         be Smart/Intelligent, Electronically Mature and facilitate Remote Building Management ;

 

         be properly shown to be Fit for Intended Use (in the Location of Use) … by CE Marking, using European Standards/Norms & European Technical Approvals (refer to Part D of the Irish Building Regulations and similar requirements in other European national building codes, European Union Safety at Work and Product Liability Legislation) ;

 

         be Super Energy-Efficient, with negligible thermal bridging and accidental air seepage … and promote and encourage, by design, Energy Conservation ;

 

         have a substantial component of Renewable Energy & Heat Technologies … sufficient to return a multiple of the building’s energy consumption to an Intelligent Regional or District Grid … and also incorporate Recycling, Rainwater Re-Use and Waste Management Technologies ;

 

         offer a high level of Indoor Air Quality, including proper protection from Natural Radon ;

 

         be Flexible and Adaptable with regard to internal layout, and Accessible for People with Activity Limitations (2001 WHO ICF) – in order to prolong Building Life Cycle and maximize Building Usability ;

 

         contain, as standard and for reasons of safety, a Domestic Sprinkler System and a remotely monitored Fire Detection System … plus a Carbon Monoxide (CO) Detection System, with a detection unit in the vicinity of each fuel burning appliance ;

 

and

 

         be Competently Built and Reliably Completed to project programme and cost estimate … with the building’s ‘Real’ Performance-in-Use capable of being tested, and continually monitored, over the complete building life cycle ;

 

and

 

         be simple and straightforward for Building Users/Occupiers to operate.

 

 

 

Principal Areas of Inadequate Performance …

 

1.  Showing Fitness for Intended Use.  Although a Single European Market for the Construction Sector exists on paper (not yet in reality) … this requirement is not well understood by manufacturers … particularly in Germany and Austria, where outdated national approaches to building product/system approval still take precedence over anything at European level.

 

2.  Domestic Sprinkler Systems.  There is a high level of resistance, among most manufacturers, to the installation of these systems.  Not acceptable !!

 

3.  Accessibility of Buildings for People with Activity Limitations.  Not well understood by manufacturers and building organizations (at all levels).  Although there is a lot of legislation in Europe covering this particular issue … it is routinely disregarded and/or very poorly implemented.  In Germany and Austria, for example, the long outdated term ‘barrier-free design’ is still in common use.  Can you believe that ?

 

4.  Radon Protection of Buildings.  Not considered important in Germany and Austria … so manufacturers just don’t bother.

 

5.  Fabric Thermal Performance.  Where building systems are ‘adapted’ for use in Ireland, I have seen thermal performance, as originally designed in Germany/Austria, seriously compromised by the installation of meter boxes and permanent ventilation openings in external walls.  Just the tip of the iceberg !

 

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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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