What is the status of the transposition of Art 25.6(EDD) and its implementation ?
Finland is in large ready for the EED article 25.6 provision, with some regulatory adjustments with explicit references to heating and cooling needed.
Larger Finnish municipalities have drafted municipal climate plans which cover strategic measures related to the supply and demand of heating. These will become mandatory for all municipalities to implement between 2025-2029*. Finland has an extensive support framework at place for municipal energy planning coordinated horizontally and vertically across levels of government. Efforts should be strengthened to build strengthened human resources for energy planning in local administrations, improve their access to data and give more emphasis to cooling aspects in their energy and spatial planning.
*At the time of writing, the incumbent government is planning to remove the obligation from the climate law
Municipal climate plans are since recently mandatory for all municipalities, which cover heating and cooling and may be integrated in land-use planning documents.
Overview of the legal frameworks per governance level in Finland
National | Finland’s main climate and energy related policy objectives are defined in the Climate Change Act, updated in July 2022. The act sets a legally binding targets for climate neutrality to 2035 and for GHG emissions reductions across sectors (excluding land use, land-use change and forestry) by 60 % by 2030, 80 % by 2040 and 90-95 % by 2050. A complementary National Climate and Energy Strategy was presented the same year. Since a 2023 amendment in the Climate Change Act (14 a § 19.1.2023/108), municipalities are obliged to submit a Municipal climate plan. The aim of the obligation is to align local climate mitigation measures to the objectives of the Climate change act. |
Regional | Most Finnish Regions have on a voluntary basis developed climate and energy related roadmaps, programmes or strategies in collaboration with municipalities. |
Local | Finnish municipalities are responsible for spatial and land use planning, the choice of heating sources for public buildings, and the ownership structure of energy companies, in which they are often the majority shareholder. District heating companies are predominantly operated as municipal corporations. Until 2018, Finnish municipalities could inscribe obligations for the connection of district heating networks to properties in spatial planning documents. Since then, they do not have such strict tools to change the heating systems for private properties. Nevertheless, zoning and land use planning is promoted nationally as strategic tools local authorities should use to facilitate renewable energy production and waste heat recovery, and to change the structure of heating supply and demand within their territories. According to chapter 14 a § (19.1.2023/108) in the Climate law 10.6.2022/423, each municipality must prepare or update its climate plan at least once per council term and issue the first one at the latest by the end of the next council period (2025-2029). While not being solely a heating and cooling plan, mandatory municipal climate plan must cover targets and measures to reduce emissions from sources within the municipality and an assessment of these sources. All current drafted municipal climate plans in Finland address measures related to emission reductions of heating through efficiency and increased renewable energy supply. By integrating spatial planning and addressing heating, municipal climate plans could be considered as de-facto heating plans. |
Content of Local heating and cooling plans according to the law
The municipal climate plans must contain:
Municipalities must practically assess measures in relation to emission reduction targets, which shall be prioritized according to their order of magnitude. Municipal climate plan may be conducted in collaboration with other municipalities, if it contains specific measures for each municipality. It may also be a part of a more comprehensive municipal land-use planning document. The plan must be open for public consultation during preparatory stages, with the specific role of participants is outlined in the general provisions of the Municipal Act (410/2015).
A favorable technical framework but limited staffing resources and restricted access to data. The removal of financial support is problematic.
Finnish municipalities benefit from technical support coordinated horizontally and vertically across levels of government. But dedicated financial support that was available for the drafting of climate plans will be removed by the current governement. The capacity for municipalities to integrate heating and cooling aspects in their strategic spatial planning is however limited by staffing shortages in local administration and limited access to sufficiently detailed and harmonised energy-related geodata.
Provided Support
Technical and organisational | 4/5 | A dedicated handbook for the preparation of a municipal climate plan (2023) has been prepared by the ministry of Environment and the Finnish Environment Institute. Municipalities are moreover provided with technical support and peer support from the Hinku network, which works as an intermediary coordinated by the Finnish Environment Institute (SYKE) under the Ministry of Environment. It involves most of the larger municipalities, Finnish institutions, the Association of Local and Regional Authorities, and numerous regions and enterprises. The network binds its members to emission reduction targets and to implementing the municipal sector’s energy efficiency agreement (KETS). Regions have also been important actors to support, coordinate and align local climate and energy plans and measures. |
Financial | 3/5 | Finnish municipalities have, like in other Nordic countries, large budgetary means to draft climate plans though the collection of municipal tax. Until 2024, the ones |
Staff & skills | 3/5 | The lack of human resources has been identified as the main challenge by Finnish municipalities for developing their climate plan, especially for smaller municipalities without staff dedicated to energy planning. Most of the existing municipal climate plans have been prepared by external contractors. Staffing shortages may be a critical issue for the drafting of heating plans, but likely more so for their implementation. This could be addressed through increased operational support to build up internal capacity in local administrations and increase the number of full-time equivalents dedicated to strategic energy planning. Municipalities can also jointly draft plans in collaboration with regional authorities, which may benefit those with smaller budgets and limited staff resources. |
Access to data | 2/5 | There are currently no available data platforms or tools that provide detailed energy related geodata that could assist municipalities in the preparation of heatng and cooling plans. Energy-related geodata used to draft climate plans are often collected and processed by external contractors. District heating companies and network operators are not obliged to publish or provide energy demand data to local authorities unless owned by municipalities. Detailed data about specific heating systems in buildings are difficult to access and is rarely updated, while spatial data for electricity and district heating infrastructure is often available. Improved access to harmonized data on energy supply and demand would be of great benefit for Finnish local administrations when preparing local climate plans that sufficiently cover strategic and spatial dimensions of heating and cooling. |