The promotion of low carbon is progressing in the real estate and construction sector. Reducing emissions from the manufacture of certain building materials and, on the other hand, the energy use of buildings has a long regulatory history. Other activities have been promoted in a market-driven manner and with voluntary agreements. To support the evaluation of low carbon, the established method is the life cycle assessment, which calculates all the CO2 emissions related to the construction, long-term use and decommissioning of the building, largely on a scenario basis.
However, the development of life cycle assessment into a credible tool that would steer low-carbon in the right way and in the right direction is still in progress. This is revealed by the Ministry of the Environment's so-called the comments given to the draft regulation of the climate assessment and the draft method based on the life cycle assessment. Considering the extent and seriousness of the matter, they cannot be ignored.
So what observations did the different stakeholders make? The qualification and eligibility requirements of the author of the climate report have not yet been defined in any way. Equally, the role of building control has not been addressed. Most building inspectors do not have sufficient substantive knowledge to be able to check the correctness of the content of the environmental report in the future. The need to update the climate assessment, which is prepared first in the planning phase and possibly reviewed during the implementation phase, has not been described in any way. What would trigger it or require it? In the end, the biggest question is whether the now proposed life cycle assessment is at all a suitable and functional method for low-carbon control and whether it can lead to overlapping or even contradictory regulation.
The calculated carbon footprint of the building depends on many different factors
The goal of the Ministry of the Environment is to produce calculation data for building type-specific limit value guidance with the planned climate survey as part of the building permit. The goal is made challenging and even impossible by various uncertainty factors, which have also been brought up in RT's reports in the past. The calculated carbon footprint of a building can vary considerably within the same building type, depending on the calculation assumptions used. The emission coefficients of energy production and the heating method and the length of the calculation period are the most significant individual factors affecting the calculation results. Other factors include the consideration of technical factors related to different material and structural solutions, which affect, for example, safety, health, living comfort and ultimately life cycle costs.
In promoting low carbon, it is important to maintain material and technology neutrality and to support innovative solutions that promote energy use and sector integration in the energy sector. The implementation method of the life cycle assessment that supports the sketches presented now, regarding the calculation of energy use during operation, is in conflict with the guidance of the current energy efficiency legislation. The situation is the same in relation to the needs of hybrid concepts of energy production in buildings and areas, which have been highlighted in e.g. in the sector integration report of the Ministry of Labor and the Economy. The drafts of the Ministry of the Environment can even steer low-carbon in the wrong direction when it comes to examining energy consumption during use.
How to credibly assess the low-carbon performance of buildings?
How, then, to develop the badly needed assessment of the low-carbon and at the same time sustainability of buildings? In order to act credibly, the starting point could be a procedure in which the life-cycle carbon footprint would be clarified in the climate assessment and how it has been reduced project-specifically by examining different alternatives. In this case, the structures and building components, building technology solutions and choices related to the form of energy that have the most significant impact on the carbon footprint would be examined. This would support comprehensive and practical consideration of the carbon footprint and its reduction, where attention would be directed to measures that have a significant impact on the project.
The procedure would also enable the carbon footprint to be reduced in a controlled manner without jeopardizing the life cycle quality and sustainability during the life cycle. The proposal promotes the development and setting of project-specific and, for example, green deal-based goals. At the same time, there would no longer be a need for an artificial building type-specific limit value setting. In this way, the need to update the constantly changing emission scenarios of energy use, which will inevitably have a direct impact on the limit values, would be avoided, which would eventually become a practically impossible task.
The broad-based opinion feedback given to the draft regulation of the Ministry of the Environment's climate assessment was welcome as it revealed the concerns of various stakeholders about the functionality of the life cycle assessment as part of the low-carbon regulation. The feedback also reveals the need for broad-based cooperation between stakeholders. This is the only way to ultimately promote low-carbon in a sustainable way - and most importantly, to commit different stakeholders to join forces to achieve the very demanding national carbon neutrality goal set by Finland. A new kind of cooperation in the real estate and construction sector and new alliances of expertise are needed to promote low-carbon and energy efficiency progressing in parallel, and at the same time more broadly sustainable construction. At last, now is the time to use them also in the development of legislation.
Pekka Vuorinen
environment and energy director
Confederation of Finnish Construction Industries (CFCI)
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