EU-kommisjonen endrer taksonomikriterier: Høringssvar fra Grønn Byggallianse, Norsk Eiendom, EBA og RIF

Response to the European Commission consultation on amendments to the EU Taxonomy Climate Delegated Act

We submit feedback on behalf of the Norwegian Green Building Council, EBA (The Norwegian Contractors Association), RIF (The Norwegian Engineering Consultancy Association) and The Norwegian Property Federation. We appreciate the opportunity to provide feedback on the proposed amendments to the EU Taxonomy Delegated Act. Our comments specifically address the criteria related to construction and real estate activities, with a particular focus on 7.1 the construction of new buildings, 7.2.

We support the Commission’s objectives with the taxonomy: to prevent greenwashing and reduce financial risk. The taxonomy’s inclusion of multiple environmental objectives ensures that we avoid a narrow focus which could have negative impacts on other environmental goals.

Our first feedback is that the Commission should clarify that projects that have started (have obtained building permits) may follow the taxonomy TSC version that applied at the time the permission was obtained. We strongly recommend adopting such an approach to avoid a ‘moving target’, especially for activities under 7.1 and 7.2, which typically extend over several years. Redesigning solutions in such projects can result in increased costs and delays, and may in some cases be impossible. Allowing projects to use the taxonomy criteria that were in place at the time of the building permit will strengthen the reliability of the taxonomy as a framework for sustainable economic activities, without significantly compromising the degree of sustainability.

Feedback on the definition of activity 7.2, renovation of buildings: We advise that a clear definition of the projects that falls under 7.2 should be made. A major renovation of a building, where all façades, the roof and technical systems are replaced, will obviously fall under category 7.2. The replacement of windows on a single façade will clearly fall under category 7.3, installation of energy-efficient equipment. However, if only one facade wall is renovated or if only fit-out works are carried out, the categorization is unclear.

Feedback on SCC to climate change mitigation for 7.1, construction of new buildings: It should be clarified that a ‘national calculation tool’ can be used to document compliance with the taxonomy criterion, even if the national calculation tool differs slightly from the ‘scope’ and ‘reporting format’ in Level(s).

Feedback on DNSH criterion regarding ‘water appliances’ for 7.1 and 7.2: It should be clarified whether this criterion applies to all building categories. The wording ‘for household use’ can be confusing. Does the criterion, for example, apply to toilets and showers in office buildings?

Feedback on DNSH criterion regarding ‘circular economy’ for 7.1 and 7.2: An increase of sorted waste prepared for reuse and material recycling from 70% to 85% is a big increase. It is unclear if this is based on statistics from the industry showing that they can deliver on these levels. In Norway, this would most likely lead to increased cost. Additionally, it should be clarified how this criterion is to be documented.

Feedback on the use of Level(s) for 7.1 and 7.2: We recommend referring to Level(s) as one of the ways to comply with the criterion, rather than making it an absolute requirement.

Feedback to the exclusion of DNSH criteria for activities 7.3, 7.4, 7.5 and 7.6: We support the exclusion of DNSH criteria for climate adaptation for these activities.