The climate report required for the building's low-carbon evaluation in the future is currently being drafted. The draft regulation has raised a lot of questions and even criticism. The statements of Rakennusteollisuus RT and other parties can be found in the statement service.
In the RT's statement, the key considerations are:
- The proposal should add a requirement for the qualification of the climate report preparer and also clarify the responsibilities of preparing the climate report in the different phases of the construction project.
- In the section on the need to update the climate assessment of the proposal, it must be clearly defined what kind of changes cause the need for an update.
- The proposal must present the uncertainty allowed for the results of the climate assessment, which is caused by the uncertainties included in the life cycle assessment (uncertainties of different initial data and calculation parameters, especially for different scenarios).
- The climate assessment must include an assessment of the functional properties of the building and the impact on the calculation results, at least in key aspects. The characteristics must be taken into account when setting the maximum limits of the carbon footprint (setting of limits for use category/building type).
- The definition of functional equivalence should be added to the definitions. This has a very significant effect on the limit values for the aforementioned low-carbon use category/building type specific limits that may be set later, where the different durability and life cycle quality factors of the buildings must be taken into account.
- In the climate assessment, the planned service life of the building should be used as the calculation period.
- Large-scale remediation should be removed from the scope of the climate assessment.
- Actions taken at the end of the building's useful life and after that should be removed from the climate assessment, because they are not predictable at all and have no effect on combating climate change.
- The carbon footprint should not be presented in the proposal at this stage, because it has not been credibly defined in the absence of commonly agreed calculation rules. The calculation formula presented now is misleading already for the reason that it adds up factors that cannot be combined.
- In particular, the biogenic carbon stock should be removed from the climate study, because its effect is most obviously to accelerate rather than restrain climate change. It is questionable at this stage to present anything related to carbon footprints before more detailed and credible background investigations.
- The justifications for the proposal must clearly describe the extent to which the proposal is actually based on the EN standards referred to and when and on what grounds it deviates from them. RT also reminds that now the Referenced Standards (especially EN 15804 and EN 16449 Calculation of biogenic/organic carbon in wood products) require an update if they are to be used for the calculation of organic carbon as suggested by the proposal
- The climate assessment and/or its justifications must include an estimate of the cost-effectiveness of the low-carbon measures (€/t-CO2).
RT also points out that the low-carbon assessment should be developed to work credibly together with the energy efficiency regulations for buildings. As presented now, the opinion proposal is contradictory with regard to energy's carbon footprint and steers in a different direction than the energy efficiency regulations for buildings, cf. the contradictions of the primary energy coefficients and the energy scenarios presented now. In order for the regulation of CO2 emissions and energy efficiency to be credible, the facilitations leading to higher CO2 emissions (E-number and U-value) for individual materials and technologies should be removed in the first place.
Pekka Vuorinen, Director of Environment and Energy