July 27th 2021

IES Supports Call for Clarity on Ireland’s Daylighting Standards

IES Supports Call for Clarity on Ireland’s Daylighting Standards

IES has recently joined forces with a number of Ireland’s leading daylighting analysis consultancies in sending a joint letter, calling on Ireland’s Minister for Housing, Local Government and Heritage to provide clarity around the country’s current daylighting standards. Coordinated by ARC Architectural Consultants, the letter has also been signed by likeminded parties Ethos Engineering, IN2 Engineering, Metec Engineering, O’Connor Sutton Cronin Consultant Engineers and Passive Dynamics. The call has also been backed by the Irish Planning Institute and the Royal Institute of the Architects of Ireland (RIAI).

This is an issue which has caused a great deal of confusion, disruption and delay for many of our customers and colleagues in Ireland on their daylight and sunlight projects, and we share the frustration. Following an initial approach to government in late 2019, we, together with our co-signatories, are ramping up our efforts, in the hopes of expediating a resolution.

The present issue stems from the fact that there are currently three principal guidance documents to which developers can refer to when assessing daylight access within a proposed development. These are:

  • PJ Littlefair’s 2011 publication 'Site layout planning for daylight and sunlight: a guide to good practice for the Building Research Establishment' (the BRE Guide)
    This sets out simple graphical methods for ensuring good daylight access within a building and is supported by several Irish statutory planning guidelines and associated documents for assessing daylight access in proposed developments. 
  • The British Standard, BS 8206-2:2008: Lighting for buildings - Part 2: Code of practice for daylighting 
    Although this was withdrawn by the British Standards Institution in May 2019, its use for assessing daylight access in proposed developments is still supported by several Irish statutory planning guidelines and associated documents, which has resulted in uncertainty.
  • IS EN 17037:2018: Daylight in Buildings
    A newly adopted standard, which is not yet referenced in any Irish statutory planning guidelines, despite assurances in the document itself stating that: “This European Standard shall be given the status of the national standard, either by publication of an identical text or by endorsement, at the latest by June 2019, and conflicting standards shall be withdrawn at the latest by June 2019.”

Each of these documents provide differing guidance with regards to minimum daylighting standards, which can have a significant impact in determining the design, height and layout of residential developments, particularly multiple-occupancy blocks in urban areas. The BRE Guide and the withdrawn British Standard suggest a 2% Average Daylight Factor for kitchens and a 1.5% Average Daylight Factor for living rooms, with the British Standard further proposing that rooms which serve more than one purpose, e.g. a combined living room/kitchen/dining room, should aim for the higher 2% value. The recommendations of the new IS EN 17037 standards equate to a requirement to achieve significantly higher daylight levels in some instances. This increase can in turn lead to radical and unwanted impacts on the form and commercial viability of a development.

As feared, this uncertainty is causing all manner of problems and delays across the industry. A recent High Court ruling (Atlantic Diamond Limited v. An Bord Pleanála & EWR Innovation Park) overturned planning permission on a development of 366 dwellings, citing that the assessment of daylight access within the proposed development had insufficient regard to BS 8206-2: 2008 - notwithstanding that this standard had already been withdrawn at the time the case was heard.

In the absence of clear guidance on what standard should be used, local Planning Authorities and An Bord Pleanála have been forced to determine their own approaches, which is creating disparity, even when it comes to developments within the same Planning Authority area. This has resulted in a guessing game for developers as to which is the correct approach for their residential developments, as well as inconsistent decision-making and delays on planning applications.

The UK has adopted a National Annex to BS EN 17037 reducing the minimum requirements for daylight access within residential developments, which has been found to have generally good correlation to previous targets for room types. It is hoped that the Department of Housing, Local Government and Heritage in Ireland could look to implement a similar solution. However, the primary aim of this letter is to urge the Department to urgently provide much needed clarification to Planning Authorities and An Bord Pleanála on the correct approach, to prevent further confusion and disruption to our clients, colleagues and the wider construction community in Ireland.

IES will be following this issue closely over the coming months and rest assured that, once a resolution is reached, we will be here to support all our customers with the relevant software, training and consultancy services you may need to comply. We will share any updates once these become available, so please watch this space for further information in the coming months.