In the Parliament, a large amount of bills is being dismantled with increasing haste. The danger is that a child, if not more, is going down with the washing water.
None of the stakeholders within its sphere of influence support the progress of the Construction Act. The low-carbon regulation of buildings has again been baked into it, when decree-making powers are applied for the assessment of carbon emissions and, at the same time, their limit values in the name of climate assessment. Both have big unsolved problems.
The development of life cycle assessment into a credible and regulatory tool that steers low-carbon in the right direction is still badly in progress. This is revealed by the comments that were given to the draft regulation of the Ministry of the Environment's climate assessment as early as the end of summer 2021. The opinion feedback revealed the concerns of various stakeholders about the functionality of the life cycle assessment as part of the regulation.
The draft regulation is now again with a statement and practically in its former form, including the former problems. If last year feedback flowed like water off a bird's back, now we can no longer afford it.
Precise regulation of figures with large uncertainties
The draft of the climate assessment does not say a word about the essential uncertainties related to the life cycle assessment. Instead, it requires the results to be reported to two decimal places, when in reality there is no certainty even about the accuracy of the numbers to the left of the decimal point. Why this, when the various uncertainties are known?
The calculated carbon footprint of a building can vary considerably within the same building type, depending on the calculation assumptions used. The starting data of the calculation from different sources is not common and accurate, and it never will be. Other factors affecting the calculation results are the consideration of technical factors related to different material and structural solutions, which affect safety, health, living comfort and ultimately life cycle costs.
The emission coefficients of energy production and the length of the calculation period are the most significant individual factors affecting the calculation results. Decarbonization of energy is progressing under its own weight, but at different speeds in different cities and municipalities. The proposed regulation's effort to force the use of different tabulated values is an artificial attempt to obtain a uniform basis for the calculation. In terms of energy use, it can be seen in the glaring differences between the actual emissions and the emissions estimated according to the climate assessment. Which leads more believably?
You should wipe the table with a carbon footprint
The most unbelievable part of the draft regulation of the climate report is the inclusion of coal in the scope of regulation as a climate benefit. Carbon footprint refers to those positive climate effects outside the building's life cycle assessment limits that would not have occurred without the construction project.
The draft regulation presents factors that cannot even be verified as climate benefits; they would only be promises for the future and not anyone's responsibility or accountability. At least for the time being, the most implausible part of the implausibly defined carbon footprint assessment is presenting the carbon store of wood as a climate benefit.
The construction industry RT made a report on this at Gaia already the other year in order to assess what can be credibly introduced into the regulation. The reports published this year by the Finnish Climate Panel and Syke, which evaluated the sustainability of wood use, confirmed the conclusions presented by Gaia.
The calculation should also take into account the change in the carbon balance of the forests and the carbon stock of the forests when the tree is removed from the forest. The carbon storage committed to wood products cannot compensate for carbon sink losses caused by increasing felling. At the same time as the carbon sinks and stores of Finnish forests are decreasing, there is simply no scientific basis for presenting carbon stores as the carbon footprint of construction.
In accordance with European standards, the draft regulation of the climate assessment states that "the components of the carbon footprint are not added together, and they are not subtracted from the carbon footprint". This has also been clearly stated on the website of the Ministry of the Environment in the questions and answers regarding low-carbon construction.
Still, a very recent publication "The use of wood in public construction" from the pen of the same ministry has just landed on my desk. It states as a "fact" about the building's carbon footprint that "to get a true picture, it is good to consider the total carbon impact, which can be calculated as the difference between the carbon footprint and carbon handprint".
Even though coal seems to be disappearing from one place to another, there is still time and an opportunity to develop low-carbon regulation in a more credible direction in cooperation between operators and legislators in the kira sector. This is actually also required by Finland's extraordinarily demanding carbon neutrality goal, which regulation should credibly support.
The solution is a project-specific alternative review of ways to reduce emissions
How, then, to develop the badly needed assessment of the low-carbon and at the same time sustainability of buildings? Standard-based life cycle assessment has been used for a long time, among other things, in voluntary environmental classifications, recognizing the related uncertainties.
In order to function credibly as part of the regulation, the starting point of the assessment could be a procedure in which the climate assessment would include as supplementary information the extent to which the carbon footprint of the most significantly affected structures and building components, building technology solutions, and choices related to the form of energy has been reduced by project-specific alternative reviews. This would support a comprehensive assessment of the carbon footprint and focus attention on the effective measures in the project.
The procedure proposed by RT and Rakli described above would enable the carbon footprint to be reduced in a controlled manner without jeopardizing the life cycle quality and durability of the building during its long service life. It could also serve as a starting point for Green Deals with a target for emission reductions. At the same time, there would no longer be a need for an artificial and speculative building type-specific limit value setting. Science and time have simply run past proposals for carbon regulation of buildings. So does the reduction of carbon emissions on a market basis.
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