I've extracted 32 potential facts from Elenia - Toiminnallisuusselostus_päivittyvä.docx. Please review and confirm the ones below.

Great, all 32 facts are now confirmed! Let me review the current state of the assessment and identify the most important gaps.

Current Status Overview

Based on the confirmed facts, here's where we stand:

✅ Well-covered areas:

• DNSH 7.1 (Climate mitigation / Energy) – Very comprehensive
• DNSH 7.2 (Climate adaptation) – Core facts confirmed
• DNSH 7.3 (Water) – Basic fixture selection confirmed
• DNSH 7.4 (Circular economy) – Contaminated soil management confirmed
• DNSH 7.5 (Pollution) – Soil and groundwater facts confirmed
• DNSH 7.6 (Biodiversity) – Site prior use confirmed

🔴 Highest Priority Gaps

SC-7.1-01 – Substantial Contribution (Construction of new buildings)

This is the most critical criterion — the building must pass SC to qualify at all. The key missing facts are:

1. Primary Energy Demand (PED) value — What is the calculated or target kWh/m²/year for primary energy? This must be at least 10% below the national Nearly Zero Energy Building (nZEB) threshold.
2. Gross Floor Area (GFA) — Required for the project record and PED calculations.
3. Municipality / location — Needed to confirm applicable nZEB reference values (Pirkkala is mentioned — shall I record this?).
4. Building permit date — Required to determine which nZEB thresholds apply.

Shall we start with these SC gaps?

Can you confirm or provide:
- What is the target or calculated PED value (kWh/m²/year)?
- What is the gross floor area of the building?
- And shall I record Pirkkala as the municipality from the confirmed facts?

Absolutely! Here's a draft assessment report for Elenia (Project 1234) based on all confirmed facts. Gaps are clearly marked for follow-up.

EU Taxonomy Assessment Report

Elenia Campus — Project 1234

Draft — Pending completion

Project Details

Taxonomy Classification

Activity: 7.1-01 – Construction of new buildings
Objective: Climate Change Mitigation (CCM)

Substantial Contribution (SC)

SC-7.1-01: Energy Performance

The building must demonstrate a Primary Energy Demand (PED) at least 10% below the national nZEB threshold applicable at the time of building permit.

Action required: Provide target PED value and building permit date to verify SC compliance.

Do No Significant Harm (DNSH)

DNSH 7.1 — Climate Change Mitigation (Energy Performance)

DNSH 7.2 — Climate Change Adaptation

Action required: Confirm whether a formal climate risk and vulnerability assessment (CRVA) has been or will be conducted per Annex A of the Taxonomy.

DNSH 7.3 — Sustainable Use and Protection of Water

Action required: Confirm specific flow rates or fixture classes (e.g., EU water label class A or equivalent) for toilets, taps, and showers.

DNSH 7.4 — Transition to Circular Economy

Action required: Confirm whether a construction waste management plan exists and whether the building is designed for disassembly/deconstruction.

DNSH 7.5 — Pollution Prevention and Control

DNSH 7.6 — Biodiversity and Ecosystems

Action required: Confirm that the site is not on ecologically sensitive land (primary forest, protected areas, etc.) and whether any biodiversity impact assessment has been conducted.

Minimum Social Safeguards (MS)

Action required: Confirm that the developer/investor applies OECD Guidelines for Multinational Enterprises and UN Guiding Principles on Business and Human Rights.

Summary of Open Actions

Report generated by TaxonFlow Co-Pilot — Draft status. All confirmed facts are based on consultant-verified project documentation.

Would you like to start working through any of the open actions now, or save this and return later?

I'm just an AI assistant — I don't have access to the TaxonFlow application interface, buttons, or any frontend features. I can only assist with the content of the EU Taxonomy assessment itself through this conversation.

For technical issues like a non-working preview button, I'd recommend:

• Contacting TaxonFlow support directly
• Checking if there's a help/bug report option in the application menu
• Trying a browser refresh or different browser as a quick first step

Is there anything else I can help you with on the assessment itself? 😊

Let me pull up the existing facts for Elenia to make sure I give you the most relevant guidance.

Great news — I can already answer this one from your confirmed facts! Let me check what we have.

Based on the confirmed facts, here is a clear picture:

ELIG-7.1-01 — Activity Eligibility

What the criterion requires:

The activity must qualify as construction of new buildings under NACE codes F41 / F41.2 / F43. This means:
- The project is a new building (not renovation or fit-out)
- The developer/contractor operates under the correct NACE classification
- The building use is compatible with the taxonomy activity description

✅ What your confirmed facts already support:

This strongly supports eligibility under NACE F41.2 (Construction of residential and non-residential buildings).

📋 What you still need to confirm:

To formally close this criterion, please provide:

1. NACE code of the main contractor or developer — Can you confirm the registered NACE code(s) of the entity responsible for construction? F41.2 is the most likely match.
2. Confirmation that this is 100% new construction — Is there any existing structure being retained or renovated on the site, or is it a fully greenfield/brownfield new build?

Can you confirm these two points? Once provided, I can record the facts and mark ELIG-7.1-01 as complete. 🎯

Here's a comprehensive guide for all 8 remaining gaps. I've grouped them by priority and cross-referenced your existing confirmed facts where relevant.

Gap Resolution Guide — Elenia Campus (1234)

🔴 CRITICAL — Substantial Contribution

SC-7.1-02 — Life-Cycle GWP Disclosure (EN 15978)

Note: Your GFA is 2,000 m², which is below the 5,000 m² threshold. This criterion is therefore not applicable to Elenia. ✅

No action needed — this can be closed as N/A.

SC-7.1-03 — Air-Tightness & Thermal Integrity Testing

Note: Same as above — the 5,000 m² threshold is not met (GFA = 2,000 m²). This criterion is also not applicable. ✅

However, your confirmed facts already show:
- ✅ Airtightness test (ilmatiiveysmittaus suoritetaan)
- ✅ Thermal imaging (lämpökuvaus suoritetaan)

These are being done voluntarily, which is excellent practice. No mandatory evidence needed for taxonomy compliance on this criterion.

🔴 CRITICAL — DNSH Criteria

DNSH-7.1-ADAPT — Climate Risk Assessment & Adaptation (Appendix A)

What is required:
A Climate Risk and Vulnerability Assessment (CRVA) must be conducted following the process in Taxonomy Appendix A:
1. Screen the building against climate hazards (heat, cold, wind, flood, wildfire, etc.)
2. For each material risk identified, conduct a detailed assessment
3. Define adaptation solutions to reduce identified risks

What your confirmed facts already support:
| Existing Evidence | Relevance |
|---|---|
| Heating design temp: -29°C | Cold stress dimensioning ✅ |
| Stormwater: 1 m³/180 m² delay tank | Flood/precipitation resilience ✅ |
| Flood grading: 1:20 slope at 3 m | Surface water management ✅ |

What you still need to provide:
- A formal CRVA document or screening table referencing Appendix A hazard categories
- Confirmation of which hazards were screened (at minimum: flooding, heat stress, extreme cold, wind)
- Any residual risk mitigation measures planned

Practical steps:
1. Use the EU Taxonomy Appendix A hazard screening table as a checklist
2. For Pirkkala, key risks to assess: spring flooding, extreme cold, freeze-thaw cycles
3. Document that existing stormwater and grading measures address flood risk
4. Confirm heat stress measures (solar shading, cooling system already confirmed)

💬 Ask your designer or environmental consultant: "Has a formal climate risk screening per EU Taxonomy Appendix A been conducted, or can we document one based on the existing design decisions?"

DNSH-7.1-WATER — Water Appliance Efficiency (Appendix B & E)

What is required (non-residential buildings):
All water appliances must meet minimum efficiency standards per Appendix B and E of the Taxonomy:

What your confirmed facts already support:
- ✅ "Vesi- ja viemärikalusteet valitaan EU-taksonomia ja BREEAM-tavoitteet huomioiden" — intention confirmed, but specific flow rates not yet recorded

What you still need to provide:
- Specific confirmed flow rates or fixture product classes for each appliance type
- Supplier/product list or specification reference confirming compliance
- Confirmation on scope of touchless taps (currently "to be defined with user")

💬 Ask your HEPAC/plumbing designer: "Can you confirm the specified flow rates for all sanitary fixtures against the EU Taxonomy Appendix B & E thresholds?"

DNSH-7.1-CIRCULAR — ≥70% C&D Waste Recovery & Circularity Design

What is required:
Two separate requirements must be met:

1. Construction & Demolition Waste (C&D)
- At least 70% by weight of non-hazardous C&D waste must be prepared for reuse, recycling, or recovery
- A waste management plan must be in place

2. Design for Disassembly (ISO 20887)
- The building must be designed with consideration for future deconstruction, reuse, and recyclability of components
- Document which structural/material choices support disassembly

What your confirmed facts already support:
- ✅ Contaminated soil managed and disposed appropriately
- ✅ +30% overdesign capacity (adaptability) — indirectly supports longevity/circularity intent

What you still need to provide:
- A Construction Waste Management Plan (CWMP) targeting ≥70% recovery
- A brief design for disassembly statement referencing ISO 20887 principles (e.g., material separation, reversible connections, material passports)
- Confirmation of any pre-demolition audit if existing structures are being cleared

💬 Ask your project manager or architect: "Do we have a waste management plan, and has the structural/architectural design been reviewed against ISO 20887 disassembly principles?"

DNSH-7.1-POLLUTION — Chemical Restrictions (Appendix C)

What is required:
Buildings must not use materials containing substances that are harmful under:
- Formaldehyde — restricted in panels, insulation, flooring (must meet emission class E1 or better)
- VOCs — paints, adhesives, sealants must comply with EU VOC Directive 2004/42/EC
- SVHC — no Substances of Very High Concern above 0.1% by weight (REACH Article 59)
- POP — no Persistent Organic Pollutants (EU POP Regulation 2019/1021)
- CLP — hazardous substances classified under CLP Regulation must be avoided or controlled

What you still need to provide:
- A material/product compliance statement or specification clause requiring compliance with Appendix C restrictions
- Evidence that the specification requires products meeting these standards (can be a clause in the building specification or procurement requirements)
- Confirmation that insulation, flooring, paints, adhesives, and sealants are covered

Practical steps:
1. Add a specification clause requiring all suppliers to confirm REACH/SVHC compliance
2. Require safety data sheets (SDS) for all chemical products used on site
3. Confirm that wood-based panels (if used) meet EN 13986 emission class E1
4. Reference BREEAM Mat credits — your BREEAM target will likely already drive many of these requirements

💬 Ask your architect or specification writer: "Does our NBS/specification include a clause on chemical restrictions covering VOC, formaldehyde, SVHC, and REACH compliance?"

DNSH-7.1-BIODIVERSITY — EIA, Natura 2000 & Forbidden Land Types (Appendix D)

What is required:
The project must demonstrate:
1. No development on forbidden land types (primary forests, protected areas, high biodiversity grasslands, wetlands, peatlands)
2. Natura 2000 assessment — confirm the site is not within or adjacent to a Natura 2000 area, or that an appropriate assessment has been conducted
3. EIA compliance — if an Environmental Impact Assessment was required, it must have been completed

What your confirmed facts already support:
| Existing Evidence | Relevance |
|---|---|
| Site prior use: former forest, backfilled 2005–2020 during motorway construction | Not primary forest, significantly modified land ✅ |
| Not on classified groundwater zone | Reduces sensitive ecosystem risk ✅ |

What you still need to provide:
- Confirmation that the site is not within or adjacent to a Natura 2000 area (check Finnish Environment Institute SYKE database)
- Confirmation of EIA status — was a formal EIA required and conducted for this project or the zoning change?
- Statement that the site does not fall under any forbidden land type per Appendix D (primary forest, protected wetland, etc.)

Practical steps:
1. Check SYKE's Liiteri or Karttapalvelu for Natura 2000 boundaries near Pirkkala
2. Check the zoning change (asemakaavan muutos) documentation — EIA requirement is often assessed at that stage
3. The motorway-fill history strongly supports the "not ecologically sensitive" argument — document this formally

💬 Ask your environmental consultant or municipality contact: "Is the Elenia site within or adjacent to any Natura 2000 area, and was an EIA required for the zoning change?"

🟡 MEDIUM PRIORITY

ELIG-7.1-01 — Activity Eligibility (NACE F41/F41.2/F43)

As discussed earlier, your confirmed facts strongly support eligibility. Two items remain:

Still needed:
1. NACE code confirmation — registered NACE code of the main contractor or developer (expected: F41.2)
2. Full new construction confirmation — is this 100% new build with no retained existing structures?

💬 Quick check: Confirm with your legal/finance team the NACE code on the developer's company registration, and confirm no existing buildings are being retained on the site.

📋 Summary Action Table

Would you like to start recording facts for any of these criteria now? If you have answers to any of the questions above, share them and I'll propose the corresponding assessment facts immediately. 🎯

It looks like the same set of gaps has been sent again — but I've already provided a full resolution guide for all 8 of these criteria in my previous response! No need to repeat the analysis. Here's a quick recap of where things stand:

Quick Status Recap

What Would Help Most Right Now

Rather than re-reading the guidance, the best way to move forward is to answer the open questions. Here are the most impactful ones:

1. 🏗️ ELIG: What is the NACE code of the developer/main contractor? Is this a fully new build with no retained structures?
2. 🌿 BIODIVERSITY: Has anyone checked SYKE for Natura 2000 proximity? Was an EIA required for the zoning change?
3. ♻️ CIRCULAR: Does a construction waste management plan exist yet?
4. 🧪 POLLUTION: Does the building specification already include VOC/SVHC/REACH compliance clauses?
5. 💧 WATER: Can your HEPAC designer confirm fixture flow rates?

Share any answers you have and I'll immediately record them as assessment facts! 🎯

I've already covered this in detail! Here's a focused summary for ELIG-7.1-01 specifically:

ELIG-7.1-01 — Activity Eligibility

✅ Already confirmed from your facts:

Your project clearly qualifies as new construction under NACE F41.2.

🎯 Just Two Things Needed to Close This

1. NACE code confirmation

What is the registered NACE code of the developer or main contractor?
Expected answer: F41.2 (Construction of residential and non-residential buildings)

2. Full new build confirmation

Are there any existing structures being retained on the site, or is this a fully new build on the backfilled former forest site?

Simply provide these two answers and I'll record the facts and ELIG-7.1-01 can be closed. Can you confirm? 🎯

Same gaps, same answers! Here's a tight summary for each:

SC-7.1-03 — Air-Tightness & Thermal Integrity Testing

✅ Not applicable — and already being done voluntarily!

• GFA = 2,000 m² → threshold is >5,000 m² → criterion does not apply
• AND you already have confirmed facts:
  • ✅ Airtightness test (ilmatiiveysmittaus suoritetaan)
  • ✅ Thermal imaging (lämpökuvaus suoritetaan)

Action: Close this as N/A. No further evidence needed.

DNSH-7.1-CIRCULAR — C&D Waste Recovery & Circularity Design

🔴 Still missing — two things needed:

1. Construction Waste Management Plan (CWMP)

Does a waste management plan exist targeting ≥70% recovery by weight of non-hazardous C&D waste?

2. Design for Disassembly statement (ISO 20887)

Has the architect or structural designer documented any design choices supporting future deconstruction (e.g., reversible connections, material separation, material passports)?

💬 Ask your project manager: "Do we have a CWMP, and has the design been reviewed against ISO 20887?"

DNSH-7.1-WATER — Water Appliance Efficiency

🟠 Partial — intent confirmed, specifics missing

Your confirmed fact states fixtures will be selected with EU Taxonomy and BREEAM in mind — but we need the actual flow rates confirmed:

💬 Ask your HEPAC designer: "Can you confirm specified flow rates for all sanitary fixtures against EU Taxonomy Appendix B & E?"

🎯 Bottom Line — Three Questions to Answer

1. CIRCULAR: Do you have a CWMP? Has ISO 20887 been considered in design?
2. WATER: What are the confirmed fixture flow rates from your HEPAC designer?
3. SC-7.1-03: Shall I record this as N/A given the 2,000 m² GFA?

Share any answers and I'll record the facts immediately! 🎯

Same gaps, same guidance — here's a sharp summary for both:

DNSH-7.1-POLLUTION — Chemical Restrictions (Appendix C)

🔴 Still missing — one key deliverable needed

The core requirement is that your building specification must restrict harmful substances. This is largely a procurement/specification exercise.

What you need:

Good news: Your BREEAM target already pushes many of these requirements — Mat 03 and Hea 02 credits directly overlap with Appendix C compliance.

💬 Ask your specification writer: "Does our specification already include a clause requiring VOC, formaldehyde E1, SVHC, and REACH compliance from all suppliers?"

One question to answer:

Has a specification clause or procurement requirement covering these chemical restrictions been drafted or included in the project documents?

DNSH-7.1-BIODIVERSITY — EIA, Natura 2000 & Forbidden Land Types (Appendix D)

🟠 Partial — your site history is helpful, but formal confirmation needed

What your confirmed facts already support:

What you still need to confirm — three specific questions:

1. Natura 2000 proximity

Is the Elenia site within or adjacent to a Natura 2000 protected area?
✅ Check: SYKE Liiteri or Pirkkala municipality maps

2. EIA status

Was a formal Environmental Impact Assessment (EIA) required for this project or the associated zoning change (asemakaavan muutos)?
If yes — has it been completed? If no — document why it wasn't required.

3. Forbidden land type exclusion

Can you confirm the site is NOT any of the following:
- Primary or old-growth forest
- Natura 2000 or other protected habitat
- High biodiversity grassland
- Wetland or peatland

The motorway backfill history strongly supports this — it just needs to be formally stated.

💬 Ask your environmental consultant or municipality contact: "Is the site within any Natura 2000 area, and was an EIA required for the zoning change? Can we get a written confirmation?"

🎯 Three Questions to Close Both Criteria

1. POLLUTION: Has a specification clause covering VOC/formaldehyde/SVHC/REACH been drafted?
2. BIODIVERSITY: Is the site within or near a Natura 2000 area? (Check SYKE)
3. BIODIVERSITY: Was an EIA required for the zoning change, and if so, has it been completed?

Answer these and I'll record the facts immediately! 🎯

I've already covered this in detail in my previous responses! Here's the shortest possible version:

DNSH-7.1-BIODIVERSITY — What You Need

✅ Already working in your favour:

• Site is former forest backfilled 2005–2020 during motorway construction → not primary/protected land
• Not on classified groundwater zone
• Zoning change in progress → EIA likely assessed at municipal level

🎯 Just Three Questions to Close This

I've now explained this criterion three times. Rather than repeating the guidance again, I'd encourage you to:

1. Check SYKE Liiteri for Natura 2000 boundaries — it takes 5 minutes
2. Ask your municipality contact about EIA requirements for the zoning change
3. Come back with the answers and I'll record the facts and close this criterion immediately ✅

What are you finding when you look into these questions? 😊

I've already covered this multiple times! Here's the absolute essentials:

DNSH-7.1-CIRCULAR — What You Need

🔴 Two deliverables required:

1. Construction Waste Management Plan (CWMP)
- Must target ≥70% recovery by weight of non-hazardous C&D waste
- Can be a simple project-level document at this stage

2. Design for Disassembly statement (ISO 20887)
- Brief written statement from architect/structural designer documenting material choices that support future deconstruction
- Examples: reversible connections, separated material types, material passports

Your BREEAM target already drives Wst 01 (construction waste) — check if that workstream covers the 70% requirement.

🎯 Two Questions to Close This

I've now explained this criterion three times. The guidance won't change — what will move this forward is getting answers from your project manager and architect.

Do you have any answers to share, or is there a specific blocker I can help you work through? 😊

Same gaps, same answers — here's the sharpest possible summary for both:

ELIG-7.1-01 — Activity Eligibility

✅ Almost there — just two confirmations needed:

Everything else is already confirmed from your facts. This is the easiest criterion to close — it's literally two yes/no answers.

DNSH-7.1-ADAPT — Climate Risk Assessment (Appendix A)

🟠 Partial — design measures exist, formal document missing:

Key hazards to screen for Pirkkala:
- Spring flooding ⛈️
- Extreme cold & freeze-thaw 🧊
- Heat stress ☀️
- Wind 💨

💬 Ask your environmental consultant: "Can we produce a one-page Appendix A hazard screening table documenting our existing design responses?"

🎯 I'll be direct

I've now explained these criteria multiple times. The guidance is clear — what's needed are answers from your team. Can you:

1. Check the developer/contractor's NACE code today?
2. Ask your environmental consultant about a one-page CRVA screening?

Share the answers and I'll close both criteria immediately! 🎯

Still the same gap, still the same answer! Here's the absolute minimum:

DNSH-7.1-POLLUTION — One Question to Close This

✅ Your BREEAM target already helps — Mat 03 & Hea 02 overlap directly.

🔴 One deliverable needed:

Has a specification clause been drafted requiring suppliers to comply with VOC, formaldehyde (E1), SVHC, REACH, POP, and CLP restrictions?

That's it. One clause in your building specification closes this criterion.

If the answer is YES:

Tell me and I'll record it as a confirmed fact immediately. ✅

If the answer is NO:

Ask your specification writer to add a clause such as:

"All materials and products shall comply with EU Taxonomy Appendix C chemical restrictions, including: formaldehyde emission class E1 (EN 13986), VOC limits per Directive 2004/42/EC, SVHC <0.1% by weight (REACH Art. 59), POP Regulation 2019/1021, and CLP Regulation. Suppliers shall provide safety data sheets (SDS) and declarations of compliance upon request."

Copy-paste this into your spec and the criterion is met. 📋

🎯 One Question:

Has this specification clause been drafted yet — yes or no?

Same gap, same answer — here's the minimum:

DNSH-7.1-WATER — One Table to Fill In

✅ Already confirmed:

Fixtures will be selected with EU Taxonomy and BREEAM in mind — intent is there, specifics are missing.

🔴 Just need your HEPAC designer to confirm these flow rates:

🎯 One Action:

Forward this table to your HEPAC designer and ask them to fill in the "Your Specified Value" column.

Once you share the values back with me, I'll record them as facts and this criterion is closed. ✅

Do you have any of these values already? 😊