Leading building science experts and designers are beginning to speak out forcefully in response the proposals being considered in Ontario’s new Building Code (OBC). They are not happy.
Take Passive House Canada (PHC) as an example. In a recently released submission of recommendations to Ontario’s Ministry of Municipal Affairs and Housing, the organization characterizes the proposed OBC as, “a big step back in improving the energy efficiency of new buildings in Ontario.”
PHC outlines several shortcomings. These include the failure to adopt outcome-based performance targets, such as Thermal Energy Demand Intensity and Cooling Energy Demand Intensity; applying the Reference Building Approach to energy efficiency modelling; and rethinking AHSRAE standards for ventilation that are excessive and counter-productive. Specific to the Passive House philosophy, the submission also outlines how OBC proposals fail to recognize the positive relationship between intentional solar gain and shading techniques and a design’s ability to lower overall heating and cooling energy costs.
PHC’s submission also challenges and rejects the oft-repeated assertions made by homebuilding lobbyists that significant improvements to building envelope construction and mandatory air tightness tests verifying homes are built as promised would significantly increase home purchase costs.
The bottom line, according to PHC, is that Ontario’s proposed building code fails to deliver the outcomes the province seeks and needs: reduced energy use and reduced carbon emissions. Specifically, it suggests, “the proposed update to the OBC is not aligned with the federal government’s or the Government of Ontario’s greenhouse gas (GHG) reduction targets.”
In conversation with the Daily Commercial News, PHC CEO Chris Ballard explained how Canada came to this crossroad.
“The National Building Code (NBC) is facilitated by the federal government with all the provinces and territories at the table, as well as all the traditional building stakeholders. But at the end of the day the National Building Code is a suggestion.”
Ballard continued that the provinces and territories can either adopt the NBC as is or use it as a base from which to improve. Despite having spent the last seven years on the 2020NBC, provinces like Ontario, Quebec and British Columbia will now take another year to finesse the NBC to meet their needs. Overall, however, there’s an expectation for harmonization across the country through a Pan-Canadian Agreement.
PHC is working successfully with all levels of governments across Canada in this process. However, with Ontario it has hit an obstacle and a flawed consultation process.
Ballard explains although the NBC won’t be released before the end of March, Ontario is asking for submissions from interested parties now. PHC wants more time.
“We know the provinces and territories all have copies. Many organizations have copies. But we don’t have a copy. Yet we’re being asked to comment on what the province is doing.”
There is a lot at stake for everyone.
For example, hundreds of municipalities have declared a climate emergency. However, Ballard says most lack the resources and expertise to develop their own building bylaws and therefore rely on guidance from the province.
Not achieving desired GHG emissions targets today only postpones the inevitable and at great expense to everyone, he says.
“We know that every day the government does not address the climate crisis means the final bill will be that much higher. We can’t continue with business as usual.”
There are also economic opportunities to be gained or lost.
“Ontario has the opportunity to show real leadership across Canada and work to build our green industry and green manufacturing. But that will only come about if the government implements high standards. Our building legislation will influence those considering making investments in this province.”
Despite current disappointment over the proposed OBC, Ballard remains hopeful.
“I’m optimistic that Ontario government will receive input from a wide variety of organizations expressing strong concerns about the OBC. I think we’ll see them revisit a lot of the more contentious problems put forward in this proposed code.”
John Bleasby is a Coldwater, Ont.-based freelance writer. Send comments and Climate and Construction column ideas to firstname.lastname@example.org.