We appreciate the opportunity to comment on the government's draft bill. Minimum energy performance requirements for buildings other than residences (including commercial, educational, and accommodation buildings, sports halls, and hospitals) are, overall, reasonably designed. They target the weakest energy classes, where measures to improve energy efficiency are often necessary anyway. A transition period until 2030 generally allows adaptation to the requirements, provided that regulation and interpretations are sufficiently clear well in advance. We deem it necessary to clarify how energy-efficiency (E) values calculated in different years and using different methods (for example, 2013, 2018, and upcoming methods) remain comparable when used as binding limit values. Exemption from exceeding the maximum energy-efficiency threshold and cost-benefit analysis The proposal notes that with certain exceptions, exceeding the energy-treshold specified in the energy certificate could be justified by a cost-benefit analysis, for instance if the payback period exceeds the building’s life cycle or remaining usable life, making the improvement not cost-effective over 20 or 30 years. We seek clarity on how building owners can practically demonstrate that such a cost-benefit analysis has been performed and meets the exemption criteria, particularly in sale situations. Additionally, ending the payback period at the end of the building’s life is not ideal; it would be reasonable to require that the building retains usable years after the payback. FINANSSIALA RY Hannu Ijäs
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