Nearly Zero Energy – Ireland’s Next Construction Scandal | Mike Morris

11 April 2017

In the following post by ‘Mike Morris “Nearly Zero Energy – Ireland’s Next Construction Scandal” 5th April 2017, the author examines the dangers of progressing towards nZeb buildings without the appropriate training or understanding of the issues involved.  Increasing insulation levels, making buildings more airtight to reduce energy loss must be accompanied by appropriate vevntilation strategies or else ‘sick’ buildings will be the result.  Link to full article “Nearly Zero Energy – Ireland’s Next Construction Scandal”. Extract:

Nearly Zero Energy – Ireland’s Next Construction Scandal

On the 20th January 2017 Simon Coveney signed S.I. 4/2017. This law is now the endgame for Ireland’s drive towards low-energy buildings, as it effectively kicks off the drive towards Nearly-Zero Energy Buildings. The Minister also began a public consultation on the 24th March, with the purpose of reviewing Ireland’s energy-efficiency regulations.

This programme is ambitious, well-intentioned and – in many ways – laudable. It is also, almost certainly, disastrous…

Insulation is complicated. And the problem isn’t just that the industry has not kept pace; the problem is that the various regulatory texts haven’t kept up either. The Homebond Manual, once a decent bible for construction, still has 1990s-esque cavity wall details that should have been junked a decade ago. The SEAI grant scheme will only pay out for internal insulation details that are technically outmoded and a condensation risk. The government’s own “Acceptable Construction Details” still include internal insulation on hollow block walls – a terrible form of construction that should quite simply be banned – but they don’t include details for a door threshold or a rooflight.

In other words, “the industry hasn’t caught up” is minimising the problem. The people who are supposed to be advising and regulating the industry haven’t caught up and, if anything, some sections of the industry are ahead of them.

This problem didn’t occur when Minister Coveney signed the act into effect. It occurred over a decade ago. Start points are always a little too neat, but 2005 is as good a place as any…

ERs [Energy Ratings] are only ever supposed to be thumbnail views on how energy-efficient a house is, they aren’t meant to be comprehensive predictions of how much energy you will use per annum. A BER is only meant to let a buyer or renter see that a house is F-rated and think “uh-oh, my bills will be high.”

The problem is that, having decided on these not-at-all researched, lick-a-finger-and-stick-it-in-the-air figures, the state also appear to have decided they are real…

What I find even more worrying, and disappointing, is that we don’t hear many voices within construction who see this complexity as a particular problem. It’s well-known that most architects can no longer calculate whether a house complies with Part L or not, but this is dismissed with platitudes about “upskilling.” Essentially, we’re asked to believe this complexity is necessary: the pre-2005 system was far too crude, this is a much more accurate assessment, and if some people find it too complicated that’s tough – there’s no alternative. And yet I’ve never seen any substantiation of this viewpoint, and Part B – that’s the fire regulations – have managed to take the complexity of fire engineering and turn it into a series of laborious, but relatively simple rules…

It isn’t just that the complexity of the current regulations is not particularly necessary; the compliance model is actually more arbitrary than a range of value limits would be. The structure penalises apartments in particular, and that’s particularly noteworthy given the wealth of new stories about apartments being currently too expensive for developers to build².

Oh yes, and in case you’re wondering – no, the move to Nearly Zero Energy Buildings won’t improve this situation. Predictably, it will make it worse….

The Building Regulations are supposed to be about climate change and energy security, not about ensuring that wealthy people can keep their houses and 20°C all day, all year round. We’re back where we were with the Reference Dwelling and EPC: a hugely complicated assessment model that actually doesn’t deliver an accurate solution. Or if you prefer, a mess…

The developers want a profit; the builders want to get it done and move on to the next thing; the architects want it to work well and look nice; the structural engineers want it to stand up. If you make it easy for these people to comply with the law, they will do it; if you give them simple rules to follow, and the resources to help them follow the rules, they’ll follow them. On the other hand, If you make laws needlessly complicated, if you drive the industry towards the use of specialists, if you utter mealy-mouthed aspirations about “upskilling the industry” while you make regulations ever-more convoluted – well, then you simply end up with a world of non-compliance. You’ll have an industry that doesn’t know how to follow the regulations, and a general public who can’t possibly hold them to account. The regulatory bodies are behaving like a Dickensian factory-owner, forcing the smallest children to carry heavier and heavier loads, outwardly ignoring their protests, already preparing to point the finger of blame at those children when they inevitably collapse.

That’s a lot to do in two years. But the alternative is to continue down the road we’re on now; the result will be bad environments, bad buildings, and millions wasted when defective insulation is removed from defective walls to reveal blockwork black with mould.

A lot of this has already gone wrong, and there’s only two years to put it right.

Other posts of interest:

nZeb are Homes of the Future | Minister Damien English

Alert | Near Zero Energy Building (NZEB)

Irish government in row over passivhaus eco building regulations | The Guardian

Building Regulations Part ‘L’ – Made Easy | Mike Morris

Design risks to comfort and health of occupiers | Architects Journal

Breaking the Mould | Joseph Little Architects

Building industry objections to passive house are deeply flawed | Passive House +

Fire Safety in Green, PassivHaus and Energy Smart Housing | CJ Walsh

Notes from the (thermal) edge: Part L Compliance (2 of 2) | Look Back 14

Part L compliance – Who wants a building control service provided by cowboys?

One ‘L’ of a battle looming over DECLG Building Regulations | Michael Tweed

Part L compliance issues – S.I.9 (1 of 2)

Part L- is compliance worth the paper its written on?

Design Certifiers – 3 things about certifying Part L… 

Why the design certifier and architect need third party building fabric assessments

Opinion piece: new building regulations and materials risk analysis

SI.9 and Part L | Specialist ancillary certifiers Part 2

SI.9 and Part L | Are specialist ancillary certifiers needed? Part 1 

3 thoughts on “Nearly Zero Energy – Ireland’s Next Construction Scandal | Mike Morris

  1. Michael Tweed

    In the course of my work through a typical winter I’m regularly asked to investigate problems of condensation and usually associated mould and mildew in apartments. In Ireland the problem is seasonal, usually starting around the beginning of October and running though to around the middle to end of April, depending greatly on the particular autumn and spring weather. The problem has little to do with how well the apartments retain heat. Apartment blocks are heat efficient because they cluster dwellings together decreasing the proportion of apartment envelope that is exposed to the elements. Rarely do I hear complaints about the cost of heating the apartment. The problem is poor ventilation leading to rapid build-up of the moisture content of the air, and usually a result of misguided reliance on natural ventilation in the apartment. Yet the guidance to the building regulations suggests compliance with energy conservation for apartments through unnecessarily excessive building insulation (and an obsession with cold bridging which I can’t understand given our temperate climate) together with compliance with ventilation through crude reliance on natural ventilation. This is the reason for poor quality apartments where black mould is the norm.
    The risk of condensation is reduced by ensuring the moisture content of the air in the apartment is low. It’s an easy correlation to remember – less moisture in the air, less risk of it turning into condensation! Which is where ventilation comes in, replacing the stale moist air with fresh air from outside. However, in Ireland through the winter the air has a low temperature and high water content (simply because we’re a small island and no matter what direction the wind blows the air travels over large bodies of water!). So the problem that the replacement air has a high water content to begin with! And here I agree with Mike Morris, the problem is complicated!
    Compliance with conservation of energy has to occur in tandem with compliance with ventilation.In order to construct good quality buildings that are both energy efficient and condensation and mould free we must use construction technology and techniques that address the unique problems presented by our indigenous climate. Using research from somewhere with a completely different set of climatic parameters won’t work. And the guidance to our building regulations in regard to conservation of energy and ventilation MUST be based on sound scientific peer reviewed research and development that is carried out in Ireland and is specific to our unique climate.
    The problems and risks addressed by other parts of the building regulations, the likes of structural stability, fire safety, sound, design of stair and ramps, and access for all are common almost world wide (with a few exceptions such as designing for earthquakes etc). But the problems and risks associated with the conservation of energy and ventilation are unique to location, geographic and most importantly climate. Part F and Part L must be absolutely specific to Ireland and Ireland only.

  2. Noel Turley

    Near Zero Carbon needs to be defined. In the UK they have clearly defined what near zero carbon is:
    The energy demand of the dwelling needs to be reduced by 35% below the current building regulations or in other words 35% below the TFEE generated by their current version of DEAP.
    The CO2 emissions is reduced significantly using renewable technologies, the annual tonnage of CO2 emissions generated by the dwelling is worked out and it is multiplied by 30 years and the tonnes of CO2 generated over the thirty years is then multiplied by £30.00.
    This carbon tax or allowable solution as it is called is then invested in projects that will be used to reduce carbon emissions. Planning permission can be refused if compliance with NZC is not proven at planning stage. NZC is in place in the Greater London Area.

  3. Michael O'Neill

    It is refrshing to read some common sense comments in relation to building regulation and how we should proceed with it

    Back in 2009 at the Plan Expo talk by the RIAI I called for the DOE to put some of their civil servants to good use commissioning a deemed-to-comply set of working drawings for a 3 bed semi – the archetypal Irish Family Home.

    I wasn’t interesting in one-eyed details showing compliance with any ONE regulation

    I wanted to see a deemed-to-satisfy set of drawings showing prima facie compliance with all regulations.
    I knew at the time there were conflicting regulatory requirements and so I wanted to see the Department get its hands dirty and have SOME kind of learning curve about the regulations they were imposing on the rest of us.

    No joy, of course. We are still waiting for such a set of drawings.

    Now we are talking about increased standards again when, as the writer suggests, the previously revised Part L standards were never assimilated properly, never mind their implications for the other 11 Regulations.

    So its time we started asking a few questions of these passive house and NZEB building standards.

    For example.

    If you are using plastic insulation externally, what stops your bhome going up like a roman candle and trapping you inside?

    The recent Millfield Manor debacle is a case in point where, mainly through good fortune, no one died

    Its good that the writer has raised the subject of increased ventilation (Part F supporting Part L)
    But far more significant issues arise in how Part L may affect Part B, Safely of Occupants from Fire

    For example:

    How do we stop cold smoke, fumes and cases migrating to the areas of sleeping occupancy in a house with an MVHR system and only the most rudimentary of fire detection and alarm systems

    How do we prevent the MVHR system’s penetrations from compromising the 30 mins Fire Resistance in the Ground floor ceiling/1st Floor soffit between the likely source of fire and the sleeping occupancy

    It seems that – in our ever-increasing drive towards thermal efficiency for our homes – we should spare a thought for how these new measures might further compromise our Life Safety strategies.


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