As part of the enactment of the Construction Act, the sections on construction waste were also updated. The goal has been to create better conditions for the utilization of construction and demolition materials and to strengthen the foundation for a circular construction economy. In our opinion, the goals of the legislative work are good in themselves, and we have recognized the need to improve the knowledge base on the various construction waste streams. However, it is still appropriate to think about what benefit would be achieved in practice by an investigation according to the regulation.
According to the Construction Act, when applying for a construction or demolition permit or submitting a demolition notice, a person embarking on a construction project must submit a demolition material and construction waste report. The report must reveal estimates of the amount of demolition materials generated in the construction or demolition project. In a new building construction project that does not include demolition, an estimate of the amount of earth and stone to be transported away from the construction site must be reported.
After the construction project is completed, the report must be updated regarding the waste information. The person embarking on a construction project should ensure that the information is reported to the demolition material and construction waste information system for each building or construction site in accordance with this regulation.
The regulation now in the opinion would provide more detail on the preparation, content and reporting of the demolition material and construction waste report in accordance with Section 16 of the Construction Act.
The key question related to the report is whether it produces added value
In connection with the reform of the Waste Act, the requirements regarding waste transfers were updated, and currently most waste shipments must be made into an electronic transfer document and the information entered into the transfer document register.
From the point of view of waste statistics, information is already being collected, and the planned survey would mainly increase reporting related to the construction project.
The situation is different for soil materials, because non-perishable soil materials are outside the transfer document obligation. With the help of the regulation, the knowledge base could be improved for a small part. By extending the transfer document obligation to also apply to soil materials, information on all soil material transports would be collected in the transfer document register, and an obligation such as the regulation would no longer be needed.
In the explanatory memorandum of the regulation, it is stated that, with regard to soil materials, the collection of data in itself encourages the soil mass balance of the construction site and the avoidance of unnecessary transportation already in the planning phase. In reality, the incentives to improve the mass balance or increase the circulation of demolition materials come from completely different sources than increasing the reporting burden.
Based on the regulation and the explanatory memorandum, the benefit of the report remains unclear. In our opinion, by developing an electronic waste transfer document and improving the usability of the transfer document register, a better end result will be achieved overall and duplicate reporting will be avoided. The goal of the government program is to streamline environmental permitting processes and remove regulatory barriers to the circular economy, so existing systems are being developed instead of new ones being developed.
Jani Kemppainen
Expert, technical requirements
jani.kemppainen@rt.fi +358 40 541 8090Building Construction Industry Association
I have come to the conclusion and understanding that recycling of demolition material is non-existent in Finland. So adding unnecessary daily reporting does not at least promote reuse.
In my opinion, the utilization of excavated lands is already difficult enough, there is no need for more pyrocracy for that either. Juha does talk about it, he will get the encouragement of the profession and all the support, I hope the matter can be taken care of. Thank you