Safety aspects of solar system construction, insulation materials, greening measures … Stimulating dialogue with the CGDIS

The Mouvement Ecologique and the Oekocentre Pafendall recently had an inspiring meeting with officials from the CGDIS (Corps grand-ducal d’incendie et de secours).

 

The meeting took place at the request of the Mouvement Ecologique. It was triggered by the fact that the Mouvement Ecologique was repeatedly confronted with the statement that certain standards were required of property developers by the CGDIS in the various approval procedures due to their competences in certain dossiers (e.g. the construction of solar installations in private homes).

 

The responsible parties explained that they would advise municipalities on buildings with 3 or more residential units or a size of 400 m2 or more. However, their opinion would only have the character of a recommendation. However, these CGDIS recommendations are sometimes adopted 1:1 by the municipalities in the provisions of the development plans (PAGs) or partial development plans (PAPs) as legally binding for individual private houses, which is not the aim and is not appropriate. The situation would be different for buildings subject to commodo requirements (i.e. generally also larger and public buildings). There, the requirements of the ITM – the Inspection du Travail et des Mines – would apply and would have to be implemented accordingly.

 

In both cases, constructions with building materials made from renewable raw materials are also permitted in principle, provided they comply with the recommended or specified fire resistance classes. However, the CGDIS is aware that appropriate fire-resistant construction methods are also possible with renewable raw materials. Those responsible made it clear that it is not the materials themselves that are relevant for them, but the fire resistance of the construction that is decisive. In this respect, even a damaged insulating façade with ‘polystyrene’ is definitely problematic.

 

It was interesting to get to know the CGDIS’s perspective on certain dossiers better. Very specific aspects were mentioned, such as Integrated solar roof tiles would not be so easy for firefighters to recognise at night, so this could pose a problem in the event of a fire (unfortunately, the CGDIS is not automatically provided with information about the building), or solar installations that were too close to the neighbouring roof could pose a problem if a firebreak had to be cut into the roof to prevent a fire from spreading to the neighbouring roof. In general, there must always be a free area on the roof that is not occupied by PV so that the fire brigade can cut an access route to the roof in the event of a roof fire…

 

As far as fire engines are concerned, which are needed to extinguish taller buildings, they would need a wider base and a wider passageway on the street would have to be guaranteed. Green structures should not stand in the way of access to the building.

 

Those responsible repeatedly stated that they were certainly open to the installation of renewable energies and more greenery. However, basic principles had to be respected for safety reasons.

 

According to those responsible, they are currently working together with the Ministry of the Interior on orientation values that the municipalities could then adopt in their land use plans or for partial development plans. This would answer questions such as: Which regulations should be respected when building solar installations? How should the handling of green structures, e.g. façade or roof greening, be regulated? Work would also be carried out on recommendations as to which building materials are recommended under which conditions.

 

The issue of e-mobility was also raised, with the CGDIS emphasising that it had no data to suggest that there was a particular risk of increased fires in this area – as is sometimes suggested in the media. The installation of e-charging stations in larger flat blocks would also not pose a problem a priori in their view.

 

The representatives of the Mouvement Ecologique and the Oekozenter Pafendall emphasised that there must be a certain balance between the demand for absolute safety and the need and desire for more greenery and the increased use of renewable energies.

 

Ultimately, it is up to the political decision-makers to make a balanced decision based on the recommendations and expert opinions. The preparation of guidelines for the municipalities – which is being carried out jointly by the CGDIS and the Ministry of the Interior, among others – is to be welcomed in this context. The voices of the environment, energy and economic ministries should also be taken into account.

 

All in all, a very open and stimulating exchange!

 

Translated by deepl.com – free version

 

14.05.24