Ar C.J. Walsh Technical Blog – Registered Architect, Fire Engineer & Independent Technical/Building Controller …… International Expert on Accessibility for All (including Fire Safety) + 'Real' Sustainability Implementation !
2014-04-13:Further to the Post, dated 2013-01-13 …
There are many essential qualities and features belonging to and representative of a Sustainable Human Environment (including the Social, Built, Virtual and Economic Environments).As discussed here many times before … Accessibility-for-All is one fundamental attribute, under Social and Legal Aspects of Sustainable Human and Social Development.
Another fundamental attribute … Urban Resilience … is now moving centre stage in the world of International Construction Research & Practice.WHEN, not if … this concept is fully elaborated and understood, it will have a profound impact on All Tasks, Activities and Types of Performance in the Human Environment … under All Aspects of Sustainable Human and Social Development.
After working for many years on Climate Change, particularly Adaptation … it was quite natural for me to encounter the concept of Resilience.But the aim of a newly established Core Task Group within CIB (International Council for Research & Innovation in Building & Construction) is to widen out this concept to also include Severe Natural Events (e.g. earthquakes, typhoons, tsunamis), ComplexHumanitarian Emergencies, (e.g. regional famines, mass human migrations), Extreme Man-Made Events (e.g. 2001 WTC 9-11 Attack, 2008 Mumbai ‘Hive’ Attacks), and Hybrid Disasters (e.g. 2011 Fukushima Nuclear Incident) … to set down Resilience Benchmarks … and to produce Resilience Performance Indicators. An imposing challenge !
AND … as Urbanization is proceeding at such a rapid pace in the BRICS Countries (Brazil, Russia, India, China & South Africa) and throughout the rest of the Southern Hemisphere … ‘practical’ and ‘easily assimilated’ trans-disciplinary output from this CIB Task Group is urgently required.In other words, the work of the Task Group must not be permitted to become an exercise in long drawn out pure academic research … the clear focus must be on ‘real’ implementation … As Soon As Is Practicable !!
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A New and Updated Groundwork …
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SUSTAINABLE DESIGN
The ethical design response, in resilient built and/or wrought form, to the concept of Sustainable Human & Social Development.
SUSTAINABLE HUMAN & SOCIAL DEVELOPMENT
Development which meets the responsible needs, i.e. the human and social rights*, of this generation – without stealing the life and living resources from the next seven future generations.
*As defined in the 1948 Universal Declaration of Human Rights … and augmented by UN OHCHR Letter, dated 6 June 2013, on the Post-2015 Development Agenda.
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The CITY (as Region)
A geographical region, with open and flexible boundaries, consisting of:
(b)A large resident population of more than 500,000 people (social environment) ;
(c)A supporting hinterland of lands, waters and other natural resources (cultivated landscape) ;
together functioning as …
(i)a complex living system (analogous to, yet different from, other living systems such as ecosystems and organisms) ;and
(ii)a synergetic community capable of providing a high level of individual welfare, and social wellbeing for all of its inhabitants.
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SOCIAL WELLBEING
A general condition – in a community, society or culture – of health, happiness, creativity, responsible fulfilment, and sustainable development.
INDIVIDUAL WELFARE
A person’s general feeling of health, happiness and fulfilment.
HUMAN HEALTH
A state of complete physical, mental and social wellbeing, and not merely the absence of disease or infirmity.[World Health Organization]
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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.
The social environment shapes, binds together, and directs the future development of the built and virtual environments.
BUILT ENVIRONMENT
Anywhere there is, or has been, a man-made or wrought (worked) intervention by humans in the natural environment, e.g. cities, towns, villages, rural settlements, service utilities, transport systems, roads, bridges, tunnels, and cultivated lands, lakes, rivers, coasts, seas, etc … including the virtual environment.
VIRTUAL ENVIRONMENT
A designed environment, electronically generated from within the built environment, which may have the appearance, form, functionality and impact – to the person perceiving and actually experiencing it – of a real, imagined and/or utopian world.
The virtual and built environments continue to merge into a new augmented reality.
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.
2013-09-10: Recently, much ado has been made in the technical press about a New Multi-Storey Office Block in Vienna which has achieved the German ‘Passivhaus’ (Passive House) Standard …
Is There A Problem ?? Yes !!
1. It takes approximately 3 Years of Building Occupation, by ‘real’ people, before the actual performance of a building can be properly monitored and reliably shown. The building is still ‘drying out’ for the first year. It takes at least one to two years of running the complex technologies and systems in today’s buildings … training people how to operate them efficiently and effectively … and fine-tuning and de-bugging as you go along … before everything begins to work together, as originally intended during the building design stage. Then, if all goes well … in the third year of occupation, the careful (i.e. accurate and reliable) monitoring of ‘real’ building performance, by means of portable measuring devices and devices installed within the construction, can commence.
So … what exactly has achieved the German ‘Passivhaus’ (Passive House) Standard … the design intent for the building, or the building’s ‘real’ performance ???
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2. Much more fundamentally … achieving this Standard is a good starting point … but in a new building project … It Is Not Enough !
A. Energy Conservation and Efficiency Burden Sharing by Different Building Types
Separate strategies are required to greatly improve the energy performance of:
existing buildings … onto which many energy efficiency measures can be successfully grafted, but it will be difficult work and will certainly not be cheap ;
buildings of historical, architectural or cultural importance … the integrity of which must be protected ; and
new buildings and facilities … which must therefore carry the major burden.
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B. Paradigm for New Buildings – A ‘Positive Energy’ Return + Assured Building User Comfort
Primary Energy Consumption should be less than or equal to 15 kWh/m2/yr.
And …
Renewable Energy and Heating Systems should contribute a reliable quantity of energy, per year, which covers the following:
i) the Building’s/Facility’s Primary Energy Consumption ;
ii) an Energy Efficiency Degradation Factor which takes account of the degradation in energy efficiency …
(a) normally expected during the life cycle of renewable energy and heating systems installed in the building. The rate of degradation will depend on the quality of maintenance and servicing ; and
(b) caused by wasteful patterns of building management and/or use ;
iii) the energy consumed by Private Transport associated with the building or facility ;
iv) an Energy Return to an Intelligent District, Local or Regional Grid exceeding, by a multiple of 3 (three), the total energy consumed by the Building/Facility (including its Energy Efficiency Degradation Factor) and any associated Private Transport.
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Notes:
Primary Energy includes the energy required to generate, transmit and distribute electricity, as well as energy directly consumed on site.
User Thermal Comfort = Air Temperature + Mean Radiant Temperature + Air Humidity + Air Velocity, i.e. draughts (ISO 7730).
Adapted to Local Context and Heritage (fr: le Patrimoine – see ICOMOS 2011) … geography, climate (incl. change, variability and severity swings), social need, culture, and economy, etc., etc.
‘Person-Centredness’ is a core value of Sustainable Human & Social Development … an essential principle in Sustainable Design … an indispensable support framework for Sustainability-related Policy and Decision-making … and an invaluable indicator when monitoring Sustainability Implementation.
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Why so because ?
It is the mid-1990’s … in the centre of Dublin City.
Imagine, if you will, a very large historical building having a civic, justice-related function … and also an enormous Energy Bill. As described in a much earlier post, dated 2009-02-20, and the series of posts which followed on the subject of Building Energy Rating (BER) … we found that the most effective and practical remedy for this gaping and continuously haemorrhaging ‘energy’ wound was to approach the problem though the building’s users, their perception of thermal comfort, and International Standard ISO 7730.
The ‘real’ reduction in energy consumption, the ‘real’ increase in the building’s energy efficiency, and the ‘real’ improvements in building user / employee comfort and morale … were astounding !
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At a 1999 Strasbourg Conference in France … I delivered the following Paper …
These are interesting times; the benefits of modern technology have bypassed and long overtaken the stirring thoughts, visions and catch cries of Architects at the beginning of the 20th Century. However, at this time in Europe, we must now ask ourselves some difficult questions …
“What should be the Design Agenda for the ‘Built Environment’ in the new millennium ?”
“Do we actually understand the ‘real’ needs and desires of ‘real’ people in an inclusive society ?”
It is Sustainable Design – the art and science of the design, supervision of related construction/de-construction, and maintenance of sustainability in the Built Environment – which is currently generating a quantum leap in the forward evolution of a more coherent design philosophy.
Principle 1 of the 1992 Rio Declaration on Environment and Development states …
‘Human beings are at the centre of concerns for sustainable development. They are entitled to a healthy and productive life in harmony with nature.’
Deeply embedded, therefore, within this philosophy is the concept of ‘person-centredness’, i.e. that core design value which places real people at the centre of creative concerns, and gives due consideration to their health, safety, and welfare in the Built Environment – it includes such specific performance criteria as: a sensory rich and accessible (mobility, usability, communications and information) environment; fire safety; thermal comfort; air, light and visual quality; protection from ionizing / electromagnetic radiation; nuisance noise abatement; etc. An important ‘person-centred’ design aid is the questionnaire survey, which is not only a very valuable source of information, but formalizes meaningful consultation between practitioners and end users.
SDI’s Guideline Framework on achieving equality of opportunity and social inclusion, which is based on a strategy produced by Directorate-General V of the European Commission, shows how further essential elements of ‘social wellbeing’ also relate to person-centredness; these include partnership between all sectors of society, consensus, transparency and openness.
This paper explores the rational and legal basis for person-centredness of the Built Environment in Europe. Fieldwork incorporating this innovative approach is also examined. Finally, a body of principles – a European Charter – is outlined which aims to ensure that new construction works, and renovated existing buildings, perform reliably, are adaptable, accessible and responsive, ‘intelligently green’ (French: intelli-verdure), cost-effective and inherently sustainable.
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CLIMATE CHANGE ADAPTATION & MITIGATION POLICIES
AND BEFORE developing Climate Change Policies which will have such dramatic impacts on human populations, and their lifestyles, around the globe … perhaps those policies would be more effective, in the ‘real’ world and in the long-term … if we looked at the problem through the ‘eyes’ of people !
It will be worth taking a look at an interesting background paper produced by the World Bank in 2009 … whether you agree or disagree with the following statements …
“A lack of citizen understanding regarding the basics of climate science is an almost universal finding worldwide even though knowledge has increased over time. Especially notable is confusion between the causes of climate change and ozone depletion, and confusion between weather and climate.”
“North Americans know far less about climate change than their counterparts in the developed world.”
“Accurate and complete understanding of information is not a prerequisite for concern.”
“Concern is widespread around the world, but it may also be inversely correlated with the wealth and carbon footprint of a nation, or the socio-economic ‘class’ within a nation.”
“In some studies, more informed respondents reported less concern or sense of responsibility towards climate change.”
“People stop paying attention to global climate change when they realize that there is no easy solution for it. Many people judge as serious only those problems for which they think action can be taken.”
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Policy Research Working Paper No.4940 (May 2009) – Kari Marie Norgaard
Click the Link Above to read and/or download PDF File (290 Kb)
This World Bank Working Paper – prepared as a background paper to the World Bank’s World Development Report 2010: Development in a Changing Climate. Policy Research Working Papers are posted on the Web at http://econ.worldbank.org
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World Bank Working Paper 4940 (2009) – ABSTRACT …
Climate scientists have identified global warming as the most important environmental issue of our time, but it has taken over 20 years for the problem to penetrate the public discourse in even the most superficial manner. While some nations have done better than others, no nation has adequately reduced emissions and no nation has a base of public citizens that are sufficiently socially and politically engaged in response to climate change. This paper summarizes international and national differences in levels of knowledge and concern regarding climate change, and the existing explanations for the worldwide failure of public response to climate change, drawing from psychology, social psychology and sociology. On the whole, the widely presumed links between public access to information on climate change and levels of concern and action are not supported. The paper’s key findings emphasize the presence of negative emotions in conjunction with global warming (fear, guilt, and helplessness), and the process of emotion management and cultural norms in the construction of a social reality in which climate change is held at arms length. Barriers in responding to climate change are placed into three broad categories: 1) psychological and conceptual; 2) social and cultural; and 3) structural (political economy). The author provides policy considerations and summarizes the policy implications of both psychological and conceptual barriers, and social and cultural barriers. An annotated bibliography is included.
2013-06-09:Further to yesterday’s post … and my use of the phrase ‘Adapted to Local Context and Heritage (fr: le Patrimoine)’ … in relation to Sustainable Fire Engineering Design Solutions … or, indeed, Sustainable Design Solutions generally …
The International Council on Monuments and Sites (ICOMOS) … has just published the hard-copy version of … ‘Le Patrimoine, Moteur de Développement : Enjeux et Projets‘ … the proceedings from the 2011 ICOMOS International Scientific Symposium, which was held in conjunction with the 17th ICOMOS General Assembly in early December 2011 … and organized by ICOMOS-France (www.icomosfrance.fr).
This bilingual (French and English) document provides a summary of the 4 Main Issues discussed during the Paris Symposium.
Manifested here … is a profound re-imagining of the concept of ‘heritage’, and its symbiotic relationship with ‘local context’ … which also now facilitates a synergetic fusion of ‘heritage’ with mainstream sustainable development theory and implementation. I have highlighted key passages …
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HERITAGE – DRIVER OF DEVELOPMENT
The Theme of the International Scientific Symposium, which forms part of the ICOMOS General Assembly, is the role of heritage in the creation of tomorrow’s society.
The effects of globalization, which are manifested in growing trends towards standardization and westernization, bring various forms of instability to human societies. Until now, heritage has been confined to the role of passive conservation of the past, and so has often been seen as a burden hindering development. In the future, it should be called upon instead to play a major role, re-establishing cultural identity and diversity as key reference points for development; these factors are currently endangered, yet vital. There is therefore a need to reassess the role of heritage in a constructive way.
The concept of heritage, which ranges from designated historic monuments to a jumble of memories, first needs a clear definition which identifies its inherent nature and sets out its boundaries and limits, now and in the future.
As it would be impossible to cover all these issues at the Symposium, it is proposed to focus on the following four issues, chosen for their fundamental importance or contemporary relevance …
Photograph taken by CJ Walsh. 2009-08-14. Click to enlarge.
1. Regional Development
As more and more people abandon small towns and the countryside, migrating to large conurbations, urban development has become anarchic, ad-hoc and difficult to control. This has already had serious, even catastrophic, results … in particular:
– The disruption of spatial scale and the loss of landmarks ;
– The breakdown of social relationships, loss of communal solidarity, concerns over security, extremist and violent demonstrations ;
– An imbalance between the city – where most concerns now focus and where most development projects take place – and the countryside, where the issue is no longer merely rural decline, but rather the complete socio-economic and cultural collapse of forgotten populations ;
– The squandering and trivialization of space, which is a non-renewable resource, and in particular the loss of landscapes and farmland, resulting from both extensive urban encroachment and land being left to lie fallow.
It is vital to return to a more balanced form of development. This will be achieved by replacing the principle of urban expansion with that of regional development, which takes into account both the countryside and secondary urban centres (small and medium-sized towns), as part of a balanced network. In this context, lessons from our heritage will again be valued as an inspiration for new developments: time-honoured frameworks, traditional plot sizes, methods of organization (urban historic core zones), communication (by land – rail – water), and energy generation (small-scale solar and hydroelectric power stations), etc.
Photograph taken by CJ Walsh. 2009-08-14. Click to enlarge.
2. Sustainable (Human & Social) Development – Return to the Art of Building !
The second half of the 20th Century was marked by the frantic exploitation of fossil fuels and is credited with the international spread of Western lifestyles and buildings, said to represent ‘progress’ but nevertheless creating a decisive break with traditional models. The goals we have today for energy saving and recycling require a fundamental change in the character of both new and old buildings, in line with the following three points:
– Expertise in Re-Use.Until the 1950’s, heritage buildings – especially vernacular ones – provided countless examples of successful adaptation to the physical environment (location, orientation, protection from sun, wind, and climate); use of local materials (earth – wood – stone, etc.); traditional techniques providing / guaranteeing the greatest opportunities to acquire and perfect artisanal skills; and an optimum capacity for recycling. The resulting buildings address today’s requirements for sustainable development particularly well. Where historic buildings are capable of residential re-use according to modern sustainability criteria, we must be able to measure and maximise their current performance before adapting them according to new artificial design standards.
– Expertise in Building.In terms of new construction, recent examples have shown the ability of traditional practices to create architecture that is indisputably creative and modern/contemporary, and offer an alternative to artificial solutions proposed in response to new standards.
– Adapting to Sustainable Living.Rather than putting the entire onus on the built heritage, we must question our expectations about comfort and utilization. We need to abandon attempts to use sites for activities for which they are fundamentally not suited; modify usage according to the seasons (closing down places that are difficult to heat in winter); and, finally, reconsider our demands in terms of comfort, which have grown excessively and unreasonably over the last decades. The progress that would be made in the fields of environmental and public health is well known.
Photograph taken by CJ Walsh. 2009-08-14. Click to enlarge.
3. Development and Tourism
Heritage is a major part of the tourist industry, but at the same time, because of the mass consumption to which it is increasingly subject, it runs the risk of becoming meaningless, by fluctuating between preservation of museum pieces and theme-park caricatures. Cut off from its context, the real significance of heritage is drowned out by a feeble reflection, and its very nature is altered by excessive numbers of visitors and the facilities installed for them.
Several courses of action are available, among others:
– Rendering identification with cultural heritage tangible … by revealing and interpreting heritage in all the richness of its context and distinctiveness, and by encouraging public awareness of history through education and the wider media.
– Controlling public access … so as both to limit physical erosion and to ensure the comfort of visitors and provide the best conditions for them to understand and appreciate the value of heritage. Some preliminary reports on trials successfully undertaken at a number of buildings and Grands Sites [designated French cultural landscapes] may help in developing guidelines.
Photograph taken by CJ Walsh. 2009-08-14. Click to enlarge.
4. Economics of Development
“The Amphitheatre at Nîmes and the Pont du Gard have brought more to France than they ever cost the Romans.” This quotation from Abbé Grégoire in the second year of the French Republic remains valid today. Investment in our heritage produces particularly attractive returns. The cultural sector fully understands this, but adopts methods that tend to be rather commercial.
This investment must be better directed, by identifying targets and striving more for qualitative results rather than short-term profits.
2013-06-08: Looking forward to some serious, collaborative and multi-disciplinary discussions on the day … and a barrel of laughs in the process (!!) …
The NUIG ‘blurb’ for the day states … “Considering the importance of aggressive energy-efficiency measures in the Building Sector, together with the requirements for a safe, healthy, comfortable (and accessible) Built Environment … this NUIG Workshop will explore the topic of Integrated Modelling and Performance of the Built Environment.”
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I was very pleased to receive an invitation to make a Presentation at this prestigious event …
‘Sustainable Fire Engineering Design’ – My Presentation Abstract
Fire Engineering … involves much more than mere compliance with building regulations and codes … whose fire safety objectives are limited, and whose performance requirements are sometimes inadequate and always minimal. More problematically … a fundamental conflict is mushrooming between Safe Sustainable Climate Resilient Building Design and Conventional Fire Consultancy Practice.
However … Sustainable Fire Engineering Design Solutions are:
Reliability-based ;
Person-centred ;
… and above all …
Adapted to Local Context and Heritage (fr: le Patrimoine – see ICOMOS 2011) … geography, climate (incl. change, variability and severity swings), social need, culture, and economy, etc., etc.
This Presentation will discuss very rich collaborative research potential in the following areas …
Creative Fire Engineering Concepts and Building Systems
Fire-Induced Progressive Damage in Buildings
Human Behaviour and Abilities in a Fire Situation
Building Design for Firefighter Safety
BMS – Fire Modelling – BIM
Research Output must be targeted at practical implementation in ‘real’ buildings … with actual user/construction performance carefully (i.e. reliably and precisely) monitored !
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If anybody out there is interested in attending this NUIG Research Workshop … please contact Ms. Magdalena Hajdukiewicz (IRUSE) at: hajdukiewicz1@nuigalway.ie
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POST-EVENT UPDATE: 2013-06-27 …
While it was difficult to keep the Workshop Programme, involving a series of short 10-minute presentation slots, on track … discussions during the day were engaging, energetic and extensive.
I happily look forward to a successful and collaborative outcome from the day … Multi-Disciplinary Teams producing Trans-Disciplinary Research Output … which is geared towards practical implementation in ‘real’ buildings, with actual construction and building user performance carefully (i.e. reliably and precisely) monitored !
Click the Link Above to read and/or download PDF File (193 Kb)
Colour photograph showing the venue for the IRUSE & The Ryan Institute (Galway University – NUIG) Built Environment Research Networking Workshop, which was held in the New Engineering Building on 24 June 2013. Seen here is Dr. Harald Berresheim during his presentation on ‘The Self-Cleansing Capacity of Our Atmosphere – Limitations on Local to Global Scales’. Photograph taken by CJ Walsh. 2013-06-24. Click to enlarge.
Click the Link Above to read and/or download PDF File (1.78 MB)
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However … and especially since the Workshop had been organized by IRUSE (the ‘SE’ standing for ‘Sustainable Engineering’) … it was indeed very strange to have to clarify the following points, among others:
1. The Minimum Life Cycle for a Sustainable Building is 100 Years … not 50 or 60 years !
2.Future Research Collaboration should be targeted at the multi-aspect ‘Sustainability Agenda’. The word ‘green’ (where only environmental aspects of sustainability are considered) should be actively discouraged, if not banned entirely !
3. With regard to Good Indoor Air Quality (IAQ) … two high-level performance indicators which 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’ … are …
– 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 should 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 should at no time exceed 800 ppm.
Concerning the substantive difference in meaning and scope between ‘sustainable’ and ‘green’ … there is, perhaps, no better way to illustrate this difference than to observe the atrocious ‘Accessibility-for-All’ Performance (Accessibility for People with Activity Limitations !) of the critically acclaimed (?!?) and award winning (?!?) New Engineering Building in Galway University … which flaunts its ‘über-green’ credentials …
Can you believe what’s in those photographs ?? More importantly … can you believe what’s not in those photographs ???? In such a recently completed building … “incredible” is the only answer to both questions.
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Under International Law … lack of accessibility, or inadequate accessibility, to the social, built, virtual and economic environments … IS a denial and infringement of the basic human rights of people with activity limitations. It also limits, needlessly and unnecessarily, the numbers of potential users of those environments … which makes no sense at all.
My strong recommendation to Galway University … is to immediately commission a Competent Accessibility Consultant to give the university campus a thorough going over ! You are failing the campus user population … the local community in Galway … and Irish society generally.
My even stronger recommendation to the Architects for the New Engineering Building … RMJM Architects (Robert Matthew Johnson-Marshall) in Scotland, and Taylor Architects in Ireland … is to always commission a Competent Accessibility Consultant on all of your projects … small, medium and large … because you haven’t a bull’s notion about this important dimension of building performance !!
And remember folks … Accessibility has been clearly specified in the new International Standard ISO 21542 as including … ‘access to buildings, circulation within buildings and their use, egress from buildings in the normal course of events, and evacuation in the event of an emergency’.
2013-05-30: Further to the recent post here, dated 2013-04-02 … and this Page on our Corporate WebSite …
Pausing … and stepping back … to consider conventional architectural practice, how architects are educated, and whether or not the professional institutes are helping, or handicapping, the forward progress of Architecture for a Better, More Sustainable World … I am deeply concerned about the future …
1. Should it be ‘Multi-Disciplinary’ or ‘Trans-Disciplinary’ ?
The word ‘trans-disciplinary’ is confusing to a lot of people … surprisingly, to many at senior levels in construction-related industries, research sectors, and academia … not just in Ireland, but internationally. The more senior the level, it seems the higher are the walls of that proverbial ‘box’. But, let me reassure you, thinking outside the ‘box’ is not confined to people in their early 20’s !!
Looking over just the initial list of Consultant Specialists in a complex architectural project … it is the task of the Architect to transform a widely ‘multi-disciplinary’ input into a coherent ‘trans-disciplinary’ output. These two concepts are very different.
Next Generation Architectural Processes and Procedures are urgently required …
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2. EU Climate & Energy Policies – Key Driving Forces for Sustainability !
Recently, the European Commission issued this Green Paper … (which, by the way, has absolutely nothing to say about Climate Change Adaptation !) …
Click to enlarge.
European Commission COM(2013) 169 final – Brussels, 2013-03-27
Click the Link Above to read and/or download PDF File (104 Kb)
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Concerning this Green Paper … Two Important Points …
(i) Current European Union (EU) Climate and Energy Policies are not just a passing fad … they are here to stay. With certainty, we also know that they will become more and more stringent … and that higher levels of performance will be mandated … not just on paper or a computer printout … but in reality, for example, in buildings which are constructed and actually occupied by ‘real’ building users. Refer also to recent findings, in Europe, about the large and growing discrepancy between car fuel efficiencies claimed after testing in a laboratory, and when later monitored under ‘real’ driving conditions.
(ii) It has now become obvious that the European Commission has lost the plot … big time ! Policies and Actions in closely related fields have been permitted to become fragmented, disjointed, and even counter-productive. Written into the EU treaties is the term ‘sustainable development’ … an intricate, open, dynamic and continuously evolving concept. However, senior levels (both political and bureaucratic) in the different Directorates-General of the European Commission have long ago forgotten, mislaid and/or lost the proper meaning of ‘sustainability’ … and the essential interdependency of its many aspects.
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… which brings me to the urgent necessity for Next Generation Architectural Design Concepts …
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In Europe … the 1990’s and early 2000’s, taken together, was a period of construction experimentation and research. We thought we could afford the resources and the lazy times … to try this, that and the other. Little emphasis was placed on practical implementation in ‘real’ buildings. However, the scale and immediacy of today’s Sustainable Development Challenges in the Built Environment have, within a few short years and much more quickly than expected, become unprecedented.
The Yanks (Gringos) are very strong on marketing … much stronger than Europe … so let’s examine a small model building … and see if its Architectural Design Concept is both coherent and comprehensive …
Mr. Amory Lovins, of the Rocky Mountain Institute in the USA ( www.rmi.org ) … has produced a very snazzy Visitor’s Guide to the sprawling complex that is ‘his home, bioshelter and office’ in Snowmass, Colorado … a Guide intended for wide public circulation.
Concerning this Building … Three Points of Interest(?) …
(i) For a fleeting moment … let us imagine that a percentage – not even all – of the vast populations living in Africa, India and China wanted the same sort of lifestyle, including the house, that Amory Lovins possesses. What would be the resource implications for this planet ??
Click to enlarge.
(ii) In a first construction ‘try’ … separate solar and/or photovoltaic panels fixed in place on a roof … attached to the building, almost as an afterthought … were the norm. Now, however, these building systems are no longer innovative … they must be properly shown to be ‘fit for their intended use’ (to comply with building regulations and codes) … and they should now be fully integrated into the architectural design concept for the building … which is not the case in the photograph above. [ Car manufacturers face a similar design challenge today … how to successfully integrate new technologies, e.g. satellite navigation screens, smartphone docking stations, usb sockets, bluetooth, etc., etc., into the front dashboard.]
Anyway … how reproducible is this model building in urban and suburban contexts … in the USA … or elsewhere in the world ?? How many people would have access to sufficient land outside a building to ‘plant’ one, or a series of photovoltaic panels ? Tracking photovoltaic panels, as shown above ?? And as seen in Italy, with those ridiculous photovoltaic fields (in a post, dated 2011-11-07 ) … good agricultural lands should not be used for this purpose … not now, not ever, never !
Photograph taken by Judy Hill Lovins. Click to enlarge.
(iii) Sustainable Buildings are ‘high-tech’ … and a very large amount and variety of electronic and mechanical equipment is necessary in order to reliably monitor and tightly control their performance … in other words, to operate a building in accordance with its design specification. Again … these services should be fully integrated into the architectural design concept for what is, no longer, just a simple dwelling. Do similar houses without basements, for example, now need a central well-ventilated service room, complete with compact workstation ?
Photograph taken by Judy Hill Lovins. Click to enlarge.
In my opinion … the Architectural Design Concept for this building is not coherent. The overall architectural impression is one of a large sprawling house, on a very large plot of land … with many different ‘environmental/energy’-related appendages, or add-ons. Can you see any coherence ?
It is the task of the Architect to consider all facets of building performance at the earliest stages of design … whether a small building, or a very large complex building … and to integrate those many diverse, but interdependent, facets into a coherent architectural statement … having a conceptual single crystalline shape … while also bearing in mind ‘person-centredness’, ‘flexibility’, ‘adaptability’, ‘accessibility for all’, and a ‘long and useful life cycle’.
[ An aside … closer to home … we are now witnessing the rise of the ‘Passive House Designer’. This person, who is able to use a specific computer software package … no less, and no more … need not necessarily be an architect, or have any architectural education/training. Is it possible to refer to the realized output from this software as ‘architecture’ … or are they merely drab, boring boxes ?? ]
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3. Sustainable Buildings, Fire Safety & Fire Engineering ?
In the elaborate Amory Lovins Visitor’s Guide above … there is only one mention of fire hazard in the building … and that is in relation to a Passive Clothes Dryer (Page 40). End of story with regard to the Fire Safety Issues for its Users … and the Fire Engineering Implications arising from a chosen architectural design and chosen construction materials and methods.
When I was referring to a centrally located service room in # 2(iii) above … that room should also be structurally hardened, and fire and smoke ‘separated’ from other spaces in the house. Or … if the service equipment is located in a roof space, there are implications for roof structural reliability in a fire situation, and the fire resistance of the ceiling construction beneath. Or … if the equipment is located in a basement, a simple intermediate timber floor construction overhead is inadequate.
Furthermore … an intelligent fire detection and warning system … and a suitable domestic fire suppression system … are no longer luxuries or optional extras, but essential requirements ! Who would want to lose such a valuable investment ??
And insofar as fire safety issues are not being considered … it seems, at all … in the case of most ‘high-tech’, sustainable buildings … and certainly not in the case of the Lovins House … the Architectural Design Concepts for these buildings ‘suffer’ from a gaping hole … an enormous void … they are incomplete and, therefore, entirely inadequate.
Fire Engineering involves much, much more than mere compliance with building regulations and codes … whose fire safety objectives are limited, and whose performance requirements are sometimes inadequate and always minimal.
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Unfortunately … there is a fundamental conflict between Sustainable Building Design Strategies and the current state-of-the-art in Fire Engineering Design. As an example … for cooling, heating and/or ventilation purposes in a sustainable building, it is necessary to take advantage of natural patterns of air movement in that building. On the other hand, fire consultants in private practice, and fire prevention officers in Authorities Having Jurisdiction (AHJ’s), will demand that building spaces be strictly compartmented in order to limit the spread of fire and smoke … thereby dramatically interfering with those natural patterns of air movement.
In everyday practice, there is a vast chasm in understanding and communication between these two very different design disciplines. As a result, serious compromises are being enforced on Sustainability Performance. If, on the other hand, adequate independent technical control is absent on the site of a Sustainable Building … it is the fire safety and protection which is being seriously compromised.
A range of critical fire safety issues (fatal, in the case of firefighters) are also arising from the Innovative Building Products and Systems being installed in Sustainable Buildings.
And because the emphasis is on pre-construction design ‘intent’ rather than the ‘real’ performance of the completed and occupied building … all of these problems are being conveniently sidestepped or ignored … and they remain hidden from everybody’s view.
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Sustainable Fire Engineering Design, on the other hand, is the creative response to Sustainable Design … and the powerful drivers of Climate Change Adaptation, and Energy Conservation/Efficiency in Buildings.
Sustainable Fire Engineering Design Solutions are …
Adapted to Local Conditions … Geography, Climate (change, variability and severity swings), Social Need, Culture, and Economy, etc., etc ;
‘Reliability-Based’ … the design process is based on competence, practical experience, and an examination of ‘real’ extreme events, e.g. 2001 WTC 9-11 & 2008 Mumbai Attacks, and 2011 Fukushima Nuclear Incident … rather than on theory alone ;
‘Person-Centred’ … ‘real’ people are placed at the centre of creative endeavours and proper consideration is given to their responsible needs … and their health, safety and welfare … and security … in the Human Environment.
Sustainability … continues to fundamentally transform our Fire Engineering, Architectural and Consultancy Practice at Sustainable Design International Ltd (SDI) !
2013-05-23: The U.N. Secretary-General, Ban Ki-Moon, announced the launch of the United Nations Sustainable Development Solutions Network (SDSN) on 9 August 2012.
UN SDSN is structured around 12 Thematic Groups of scientific and technical experts – from academia, civil society, and the private sector – who work in support ofSustainable Development Problem Solving at local, national, and global scales … and to identify and highlight best practices. They also provide technical support to the High-Level Panel of Eminent Persons on the Post-2015 Development Agenda.
The world has changed profoundly since the year 2000, when the UN Millennium Declaration and the Millennium Development Goals (MDG’s) were adopted by the United Nations. Four critical shifts make the coming fifteen-year period, 2015-2030, different from the MDG period, 2000-2015: (i) a drastically higher human impact on the physical Earth; (ii) rapid technological change; (iii) increasing inequality; and (iv) a growing diffusion and complexity of governance.
These problems will expand, dangerously beyond our control, without an urgent and radical transformation in how we organize society. The world now needs an operational Sustainable Development Framework which can mobilize all key actors (national & local governments, civil society, business, science and academia) in every country to move away from the Business-as-Usual (BaU) Trajectory towards a Sustainable Development (SD) Path. This Framework and the SDG’s identify the main objectives and strategies needed to transform from BaU to SD.
The purpose of the Sustainable Development Goals (SDG’s) is to help translate global aspirations into practical actions. In this regard, SDSN has subscribed to the ‘Rio+20’ Agreement that the SDG’s should be ‘action-oriented, concise and easy to communicate, limited in number, aspirational, global in nature and universally applicable to all countries while taking into account different national realities, capacities and levels of development, and respecting national policies and priorities’.
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SDI’s Comments on the Draft ‘Action Agenda for Sustainable Development & Sustainable Development Goals’ …
[ Submitted by e-mail, yesterday (2013-05-22), to the U.N. Sustainable Development Solutions Network.]
1.The problems with this Draft Document, dated 7 May 2013, are fundamental and profound. Our Organization will be happy to assist the Network (SDSN) in improving the text.
2. At this time, however, we would like to bring to your attention some urgent overarching issues:
Amend the Title … refer directly to the Sustainable Development Goals (SDG’s). See above.
As drafted, the text does not show that … or explain how … there is a robust Interdependence between the different Sustainable Development Goals.
Indeed, the scale and immediacy of the Sustainable Development Challenges are unprecedented. The Network (SDSN) must now, therefore, take the brave and difficult step of placing the Sustainable Development Goals in order of priority. Do not allow yourselves to be shackled by the approach taken in the earlier Millennium Development Goals !
In this Document, All of the texts dealing with ‘Governance’ are ambiguous, weak and embarrassingly inadequate. References to the Institutional, Political, Legal and Judicial Aspects of ‘Governance’ are both necessary, and required.
The word ‘access’ is used very often and very generally in the Document. BUT … in order for People with Activity Limitations (2001 WHO ICF) to ‘access’ facilities and services in the Built (including Virtual), Social and Economic Environments, and to be included and participate fully in their local communities … it is an ESSENTIAL prerequisite that those Environments are effectively ACCESSIBLE-FOR-ALL ! This concept is not mentioned once in the Document … a very serious omission.
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Updates: 2013-06-07 & 2013-07-22 …
The SDSN Final Report is Fundamentally and Profoundly INADEQUATE !
Immediately below that … see Extracts from the Letter of Navanethem Pillay, United Nations High Commissioner for Human Rights, dated 6 June 2013 … addressed to All Permanent Missions in New York and Geneva.
Click the Link Above to read and/or download PDF File (1.91 MB)
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” Twenty years ago this June, the World Conference on Human Rights convened at Vienna to forge a new vision for our world, one founded on a recognition of the fundamental interdependence between democracy, development and human rights. In the tail of a blood-stained and deprived century, the whispered call was for dignity, equality, justice, rights. And what began as a murmur in Vienna grew in volume and force with each global conference: Copenhagen and Beijing in 1995, Durban in 2001, New York in 2005 and again in 2010, and Rio in 2012. In recent years, the murmur has become a roar, echoing across societies on all continents, from victims denied redress, older persons denied respect, youth denied hope, and activists demanding a better way. From this call, we have learned much about the imperatives of sustainable development. There will be no development without equality, no progress without freedom, no peace without justice, no sustainability without human rights.”
“All that is required is the political will to move beyond the failed approaches of the past, to chart a fresh course, and to embrace a new paradigm of development built on the foundation of human rights, equality and sustainability.”
1.The Post-2015 Agenda must be built on a human rights-based approach, in both process and substance.
2.The new agenda must address both sides of the development challenge – that is freedom from both fear and want.
3.The imperative of equality must underpin the entire framework.
4.Marginalized, disempowered and excluded groups, previously locked out of development, must have a place in the new agenda.
5.We must commit to ending poverty.
6.The new framework must advance a healthy environment, as an underlying determinant of internationally guaranteed human rights.
7.The Universal Declaration of Human Rights guarantees the right to an international order in which human rights can be fully realized. Similarly, the UN Declaration on the Right to Development mandates international reform to ensure human rights-based policy coherence at the international level. In the wake of the global financial, food, climate and energy crises, and in the context of growing disparities and historic governance failures at all levels, the credibility and effectiveness of the Post-2015 Agenda will therefore depend also on the degree to which it addresses this pressing need for human rights-based reforms at international level.
8.The Post-2015 Agenda should be universally applicable.
9.The Post-2015 Agenda must include a strong accountability framework.
10.In the wake of the devastating global financial crisis, and revelations of abusive business practices in all regions, it is clear that responsibility for human rights-based development in the Post-2015 period must extend to actors in the private sector, as well.
Submissions on India’s Draft Amendment No.1 to the 2005 National Building Code (SP 7:2005) concerning the Proposed Incorporation of a New Part 11: ‘Approach to Sustainability’ had to arrive at the Bureau of Indian Standards (BIS), in Dilli … by e-mail … no later than Friday last, 15 March 2013 …
Click to enlarge.
Indian NBC, Proposed Part 11 on ‘Sustainability’ – December 2012 Consultation
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Extract From Foreword (Page 7):
‘ Developed nations’ approach to sustainability generally concentrates on energy conservation through high technology innovations, and use of products, materials and designs with lower embodied energy. Their green ratings are based on intent, which implies expert inputs and simulation. The Indian construction industry will do better using our traditional wisdom and practices, building in harmony with nature through regional common knowledge, consuming as little as necessary, applying low cost technology innovations, using recycled materials, and recognizing performance (not intent) through easily measurable parameters wherever feasible.’
How Right They Are About Prioritizing ‘Real’ Performance !!
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And Just Before That Extract Above:
‘ The authentic (my insert !) Indian way of life is aparigraha (minimum possessions), conservation (minimum consumption), and recycling (minimum waste). These three attributes are the guiding principles for sustainable buildings as well. With these attributes and its rich heritage, India can make a substantial contribution in this field and eventually lead the world on the path of sustainability.’
An Overly Ambitious Target ? Perhaps Not.
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SDI Supporting India’s National Sustainable Buildings Strategy …
We very much welcome this opportunity to make a Submission on India’s Draft Amendment No.1 to the 2005 National Building Code (SP 7:2005) concerning the Proposed Inclusion of a New Part 11 ‘Approach to Sustainability’.
This IS an important development for India … and it DOES mark a substantial contribution to this field, at international level. We wish that other countries would follow your example … particularly China, the other mushrooming economies in South-East Asia, and the Arab Gulf States.
You may not be aware that Sustainable Design International (SDI) has been specializing in the theory and implementation of a Sustainable Human Environment (social, built, virtual, and economic) since the mid-1990’s.
And, for example … in September 2007, we were invited to make a series of Keynote Presentations to 20 Senior National Decision-Makers, from both the public and private sectors, at a 2-Day Workshop which was organized for us in Lisboa, Portugal. If invited, we would be delighted to repeat this valuable exercise in Dilli, Bengaluru, and other suitable venues in India.
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IF India is to lead the world on this particular track, i.e. Sustainable Buildings, a coherent philosophy must be outlined in the Proposed New Part 11 of the National Building Code, and a clear direction must also be given there to decision-makers, e.g. clients/client organizations, and designers.
Certain essential content must be included in Part 11. With regard to an improved layout of Part 11, please review the attached SDI Document: ‘SEED Building Life Cycle’ (PDF File, 55 Kb) .
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Because you have prioritized ‘real’ building performance over pre-construction design ‘intent’, it is appropriate to begin our comments here …
1. Sustainability Performance Indicators
In order to prioritize ‘real’ performance, the monitoring of actual sustainability performance in completed and occupied buildings must be comprehensive, accurate and reliable. Indicators of sustainability performance must, therefore, be included in all sections of the Proposed New Part 11.
Sustainability Performance Indicators provide important signposts for decision-making and design in many ways. They can translate physical and social science knowledge into manageable units of information which facilitate the decision-making and design processes. They can help to measure and calibrate progress towards sustainable development goals, and sectoral sustainability targets. They can provide an early warning to prevent economic, social and environmental damage and harm. They are also important tools to communicate ideas, thoughts and values because, as statisticians say: “We measure what we value, and value what we measure”.
Performance Indicators may be both quantitative and qualitative … but must cover all stages of the building process, i.e. project feasibility and performance specification, spatial planning, design, construction, management, operation, maintenance and servicing, de-construction, disposal, final site clean-up and sustainable repair.
While many, though not all, types of building performance can be successfully monitored using lightweight portable equipment … a certain number of monitoring devices must also be permanently installed in the building during construction. A facility to reliably feed the output from these devices back to data collection points, on site and remote, must also be incorporated in the Building’s Intelligent Management System.
Management and collation of sustainability performance data must be reliable. Uncertainty is always present. Therefore, Statements of Uncertainty should always be attached to ‘reliable’ data.
Safety Factors should always be included when targeting critical ‘health and safety’ related types of performance.
Sustainability Performance Indicators must be directly comparable across different Global Regions … within Asia, across different countries … and within India, across different States. A Balanced, Harmonized Core Set of Indian Performance Indicators should be quickly developed. A Balanced ‘Local’ Set of Performance Indicators will always be necessary.
People tasked with monitoring sustainable building performance must be competent … and independent, i.e. be unconnected to client, design and construction organizations.
Specifically in relation to Energy Performance, the targets to be achieved in new buildings must be far more ambitious. Please review the attached SDI Document: ‘SEED Positive Energy Buildings’ (PDF File, 29 Kb) .
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2. Properly Defining ‘Sustainable Development’
As currently drafted … Definition 2.26 Sustainable Development, on Page 13 of the Proposed New Part 11, is not only ambiguous, it is inadequate for India’s needs … and it is barely the first half of the full, correct definition …
Sustainable Development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs. It contains within it two key concepts:
the concept of ‘needs’, in particular the essential needs of the world’s poor, to which overriding priority should be given ; and
the idea of limitations imposed by the state of technology and social organization on the environment’s ability to meet present and future needs.
[ Please refer to the 1987 Report of the World Commission on Environment & Development (WCED): ‘Our Common Future’ – Chapter 2, Paragraph 1.]
This original definition in the 1987 WCED Report IS appropriate for India … and it must become the core definition at the heart of India’s National Sustainable Buildings Strategy !
A careful reading of the full definition makes it clear that there are Many Aspects to this intricate, open, dynamic and still evolving concept … the most important of which are: Social, Economic, Environmental, Institutional, Political, and Legal.
It is a Fundamental Principle of Sustainability, and one of its Primary Values … that Implementation must be Synchronous, Balanced and Equitable across All Aspects of Sustainability.
The ‘Green Agenda’ merely considers Environmental Aspects of Sustainability … in isolation from all of the other Aspects ! This is a fatal flaw which must be avoided in the Proposed New Part 11 !!
[ I made many references to this issue during the FSAI Conferences in India ! ]
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3. Sustainability Impact Assessment (SIA) for India !
Rather than Environmental Impact Assessment … surely the Proposed New Part 11: ‘Approach to Sustainability’ must now use, explain and discuss Sustainability Impact Assessment instead !?!
Sustainability Impact Assessment (SIA)
A continual evaluation and optimization assessment – informing initial decision-making, or design, and shaping activity/product/service realization, useful life and termination, or final disposal – of the interrelated positive and negative social, economic, environmental, institutional, political and legal impacts on the synchronous, balanced and equitable implementation of Sustainable Human & Social Development.
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4. A Robust Legal Foundation for ‘Sustainable Human & Social Development’
Paragraph 4 (Chapter 2, 1987 WCED Report) states …
‘ The satisfaction of human needs and aspirations is the major objective of development. The essential needs of vast numbers of people in developing countries – for food, clothing, shelter, jobs – are not being met, and beyond their basic needs these people have legitimate aspirations for an improved quality of life. A world in which poverty and inequity are endemic will always be prone to ecological and other crises. Sustainable development requires meeting the basic needs of all and extending to all the opportunity to satisfy their aspirations for a better life.’
Trying to list the essential needs of people / the basic needs of all is a very difficult task … but it is work which has been on-going, at international level, since just after the Second World War.
The essential needs of people / the basic needs of all … are specified as being Human Rights and Fundamental Freedoms, and are already fully described within the extensive framework of International Legal Rights Instruments.
Which is why, many years ago, SDI developed this definition for Sustainable Human & Social Development … in order:
to give this concept a robust legal foundation ; and
(because of widespread confusion in media, political and academic circles) … to clearly establish that we are talking about sustainable human and social development, and not sustainable economic development, or any other type of development !
Sustainable Human & Social Development
Development which meets the responsible needs, i.e. the Human & Social Rights*, of this generation – without stealing the life and living resources from future generations … especially our children, and their children … and the next five generations of children.
*As defined in the 1948 Universal Declaration of Human Rights.
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5. Climate Change Adaptation & Resilient Buildings in India ?
Atmospheric Ozone Depletion and Climate Change are mentioned, here and there, in the Proposed New Part 11. The important implications of these phenomena for Sustainable Building Design in India are not explained … at all. Why not ?
To properly respond to these phenomena, both must be integrated into India’s National Sustainability Strategies & Policies.
At the very least … we strongly recommend that Design Guidance on Climate Resilient Buildings be immediately drafted. This guidance must be appropriate for implementation in each of the different climatic regions of India.
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6. A Sustainable Indian Built Environment which is Accessible for All !
Barrier Free is mentioned, here and there, in the Proposed New Part 11. This is to be warmly welcomed and congratulated. Under Social Aspects of Sustainable Human & Social Development … this is an essential attribute of a Sustainable Built Environment ! However, no guidance on this subject is given to decision-makers or designers. Why not ?
However, you should be aware that India ratified the United Nations Convention on the Rights of Persons with Disabilities (UN CRPD) on 1 October 2007. For your convenience, I have attached copies of the Convention in English, Hindi and Tamil.
You should also be aware that, in December 2011, the International Standards Organization (ISO) published ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’. In its Introduction, ISO 21542 is directly linked to the U.N. Convention … almost like an umbilical cord. The scope of this Standard currently covers public buildings. As the Accessibility Agenda in the U.N. Convention is very broad … much standardization work remains to be finished at international level.
The correct term … Accessibility for All … has been defined in ISO 21542 as including … ‘access to buildings, circulation within buildings and their use, egress from buildings in the normal course of events, and evacuation in the event of an emergency’.
A note at the beginning of the standard also clarifies that Accessibility is an independent activity, i.e. assistance from another person should not be necessary … and that there should be an assurance of individual health, safety and welfare during the course of those (accessibility-related) activities.
In order to fulfil India’s legal obligations as a State Party to the U.N. Convention on the Rights of Persons with Disabilities … adequate Design Guidance on Accessibility must be included in the Proposed New Part 11, supported by ISO 21542.
In addition, the Bureau of Indian Standards (BIS) should immediately adopt ISO 21542 as the Indian National Standard on Accessibility for All … IS / ISO 21542.
[ I made many references to this issue during the FSAI Conferences in India ! ]
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7. Fire Safety & Protection for All in Sustainable Indian Buildings ?
Yes … there is 1 mention of ‘fire safety’ and 40 other references to ‘fire’ in the Proposed New Part 11 … but no design guidance. Why not ?
You should be aware that there is a fundamental conflict between Sustainable Building Design Strategies and the current state-of-the-art in Fire Engineering Design. As a good example … for cooling, heating and/or ventilation purposes in a sustainable building, it is necessary to take advantage of natural patterns of air movement in that building. On the other hand, fire engineers in private practice, and fire prevention officers in Authorities Having Jurisdiction (AHJ’s), will demand that building spaces be strictly compartmented in order to limit the spread of fire and smoke … thereby dramatically interfering with those natural patterns of air movement.
In everyday practice, there is a vast chasm in understanding and communication between these two very different design disciplines. As a result, serious compromises are being enforced on Sustainability Building Performance. If, on the other hand, adequate independent technical control is absent on the site of a Sustainable Building … it is the fire safety and protection which is being seriously compromised.
A range of critical fire safety issues (fatal, in the case of firefighters) are also arising with the Innovative Building Products and Systems being installed in Sustainable Buildings.
Because the emphasis is on pre-construction design ‘intent’ rather than the ‘real’ performance of the completed and occupied building … all of these problems are being conveniently ignored, and they remain hidden from everybody’s view.
This must be addressed in the Proposed New Part 11.
[ I made many references to this issue during the FSAI Conferences in India ! ]
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C. J. Walsh – Consultant Architect, Fire Engineer & Technical Controller – Managing Director, Sustainable Design International Ltd. – Ireland, Italy & Turkey.
2013-02-28: Submissions on Ireland’s Draft National Radon Control Strategy must arrive at the Department of the Environment, Community & Local Government, our national authority having jurisdiction … by e-mail or hand delivery to either the Custom House in Dublin or the DECLG Offices in Wexford … no later than 17:30 hrs tomorrow, Friday 1 March 2013 …
Click the Link above to read/download PDF File (425 Kb)
The Aim of this Draft Strategy, as stated on the DECLG WebSite, is to ensure that exposure to Radon Gas, which presents a significant public health problem, is addressed in an effective and co-ordinated way across all relevant public authorities through appropriate interventions. The Draft Strategy was developed by an Inter-Agency Group comprising representatives from relevant public authorities.
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After all of the progress made on radon protection in buildings at the end of the 1990’s and beginning of the 2000’s, it is extremely disappointing to read this miserable excuse for a strategy document. If the general public in Ireland is under any impression that the ‘powers-that-be’ are deeply concerned about protecting our health … they are making a fatal mistake !
The complete absence of any reference to a Recommended Health-Related Radon Target Level – Safety-Related National Reference Levels which are not clearly explained will result in some injury and harm – Lack of Meaningful Consultation with, and Informed Consent of, the National Population – Horrendously Inadequate Technical Control Procedures on Irish Building Sites – RPII Recommended Indoor Radon Activity Measuring Devices having Very High Measurement Uncertainty (±30% under typical conditions of use) – A Purposeful Lack of Detailed Guidance on Exactly When and How to Measure Indoor Radon – Inadequate RPII Radon Measurement Test Reporting … are just some of the tell-tale signs for a seasoned observer.
In this regard, therefore … and let me be very clear and simple in my use of language … this Draft National Radon Control Strategy is a blatant fraud !!
Fraud: Deliberate deception, trickery, or cheating intended to gain an advantage – An act or instance of such deception (from Latin Fraus (f): deceit, deception).
Furthermore … the Inter-Agency Group which produced this Draft National Radon Control Strategy for the DECLG Minister, Mr. Phil Hogan T.D., and Senior Civil Servants within the Department … whoever the Group’s participants are, wherever they are … should be thoroughly ashamed of themselves for being associated with this negligent act !
Negligent: Lacking attention, care or concern.
Negligence: A wrong whereby a person(s) is in breach of a legal duty of care, resulting in harm or injury to another person(s) … in this case, the Irish Public.
To see a complete overview on this Serious Building-Related Human Health Issue, and for information about a Far Better and More Coherent Approach to Radon Protection in Buildings which takes proper account of European Union (E.U.) legislation, e.g. the Precautionary Principle … please refer to SDI’s Corporate WebSite …
SDI’s Comments on Ireland’s Draft National Radon Control Strategy (NRCS)
1.Protecting Human Health versus Reducing Risk to Safety
The following two short extracts from 1. Introduction and Background in the Draft NRCS reveal the true intent of the Inter-Agency Group …
‘ Radon gas is the greatest source of exposure to ionising radiation for the general public and is the second greatest cause of lung cancer in Ireland. Recognising the serious health risk presented by radon, the Minister for the Environment, Community and Local Government in November 2011 established an inter-agency group to develop a National Radon Control Strategy (NRCS).’
and …
‘ During 2012 the inter-agency group developed a draft NRCS based on wide stakeholder consultation and a health economics evaluation of different radon intervention strategies. The stakeholder consultation involved a range of individuals and bodies involved in: health care, construction, radon services, Government and academia. The health economics evaluation was undertaken by the Radiological Protection Institute of Ireland (RPII) and Health Service Executive (HSE) with the assistance of the Health Economics Unit at the University of Oxford. This draft strategy sets out a range of measures to reduce the risk from radon to people living in Ireland.’
Radon is a serious human health issue, and it is explained in a later section of the document 1.2 The Radon Problem in Ireland that ‘indoor radon is linked to between 150 to 200 lung cancer deaths each year in Ireland, which equates to approximately 13% of all lung cancer deaths.’
However … after the references above to ‘health economics evaluation’ (!) … to the ‘prevailing economic situation’ (!!) in section 1.1 Public Consultation … and to ‘health economics tools’ (!!!) in section 2. Draft National Radon Control Strategy … etc … you should then sensitize yourself to the subtle change in language very early in the document … from a consideration of health protection, to reducing the risk from radon (or similar variations on that theme).
The concept of Protecting Human Health is altogether different from the concept of Assessing and Mitigating / Reducing Risk to Safety ! Please refer to SDI’s Corporate WebSite.
As far back as the end of the 1990’s … the Irish Agrément Board, which at the time included a representative from the Department of the Environment, accepted the following …
Radon Activity in Buildings – Recommended Target Health Level
Radon Activity (incl. Rn-222, Rn-220, RnD) should, on average, fall within the range of 10-40 Bq/m3, but should at no time exceed 60 Bq/m3.
This Recommended Target Health Level for Radon now also appears in International Standard ISO 21542: ‘Building Construction – Accessibility & Usability of the Built Environment’, which was published in December 2011. Please refer to Annex B.8 – Indoor Air Quality (IAQ) in the ISO Standard.
The Draft NRCS must refer to such a Recommended Target Health Level … and it must be stated that it is National Policy to progressively reach that target by 2025 (bearing in mind the ‘prevailing economic situation’ in the country !).
Note: In contrast to the above … 200 Bq/m3 for Residential Buildings, and 400 Bq/m3 for Workplaces … are NOT Health-Related Target Levels … they are Safety-Related National Radon Reference Levels which result in some measure of harm and injury to people … particularly children under the age of 10 years, and people with activity limitations who constantly remain indoors for prolonged periods of time.
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2.National Policy Priority: ‘Real’ Protection from Radon in ‘Real’ Irish Buildings
Yes … in Ireland, we have enormous problems with regard to a lack of awareness among the general population about the serious health hazard posed by indoor radon … and the absence of proper education and training for everyone directly involved in the design, construction, management, operation, servicing or maintenance of our building stock (both new and existing).
BUT … if we are committed to providing ‘real’ radon protection in ‘real’ Irish buildings, then a practical construction-oriented approach is demanded.
This is a Key Paragraph in 2.1 Radon Prevention in New Buildings …
‘ The stakeholder engagement also points to some practical difficulties associated with the implementation of the current technical guidance on radon prevention. These difficulties relate to the correct installation of radon barriers under site conditions, protection of the integrity of radon barriers once installed and identification of radon preventive measures on site. The stakeholder engagement also indicated the system of building control in place prior to 2012 did not provide adequate assurance that radon preventive measures had been correctly installed ‘
… which we later discover is a masterstroke of understatement and evasion, because none of these important issues are tackled head on in the document.
On the critical issue of Building Control … there is no mention of mandatory inspections of construction projects by competent Local Authority personnel. Because … it remains the unwritten policy of Ministers and Senior Civil Servants in Ireland’s Department of the Environment, Community & Local Government (DECLG) that Local Authority Building Control Sections will be entirely ineffective.
On the other hand … will Competent Private Independent Technical Controllers be facilitated in carrying out sufficient inspections of all radon protection related works before ‘signing off’ on proper completion ???
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3.Regulatory Status of RPII’s Radon Prediction Maps
This is NOT a problem unique to Ireland.
The presence of the RPII Radon Prediction Maps in Technical Guidance Document C (Building Regulations), and the status they are given there … are both entirely inappropriate.
While these Maps are a useful design aid, in the case of small construction projects, they offer NO assurance of certainty to either building designers or users. They are NOT reliable ! And the average values shown in any particular ‘box’ may actually conceal a considerable degree of variability in the radon concentrations found in completed buildings.
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4.SDI’s Acceptance of RPII Services
Please refer to SDI’s Corporate WebSite.
Unfortunately, until the Radiological Protection Institute of Ireland (RPII) includes proper statements of Measurement Uncertainty in its Test Reports (this is a requirement of European Standard EN ISO/IEC 17025) … our Organization:
cannot recommend any RPII Radon Testing Services to 3rd Parties ;
and
will not accept any RPII Test Reports as proper evidence of Radon Test results.
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C. J. Walsh – Consultant Architect, Fire Engineer & Technical Controller – Managing Director, Sustainable Design International Ltd. – Ireland, Italy & Turkey.
