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Performance versus prescriptive: The 2020 NBC raises housing industry concerns

John Bleasby
Performance versus prescriptive: The 2020 NBC raises housing industry concerns

Attempts to incorporate a tiered energy Step Code into Canada’s National Building Code (NBC) has resulted in significant feedback from organizations representing the residential construction industry.

This feedback forms part of NRCanada’s public review process for a revised NBC, due to be published later this year.

The NBC changes are part of the Pan-Canadian Framework (PCF) on Clean Growth and Climate Change, announced by Canada’s first ministers in 2016 as part of the country’s commitment to meet climate objectives.

Many of the proposed 2020 NBC amendments effecting homebuilding focus on energy and are modelled after British Columbia’s Energy Step Code,  a five-level energy performance scale that places Net Zero Ready at the top. B.C.’s tiered approach to residential energy performance allows municipalities in that province to choose their own level of energy efficiency over and above standard code.

However, B.C.’s Step Code has not been without controversy since its adoption in 2017. Introducing a similar performance-based energy code at the national level, versus a traditional prescriptive approach, has some industry experts worried as well.

Casey Edge, executive director of the Victoria Residential Builders Association, is concerned that governments at the federal and provincial levels are abandoning the primary purpose of building codes — health, safety and consumer protection — in favour of fast-tracking energy efficiency.

“Many communities across the country lack the resources and local expertise to achieve performance testing,” explained Edge. Furthermore, he says remote areas are further disadvantaged by the high costs of performance testing, even when available in their area.

Concerns have also been raised regarding the officials overseeing building codes.

In feedback published in the minutes of the 18th meeting of the Task Group on Energy Efficiency in Housing and Small Buildings, Jack Mantyla, director of technical services with the Canadian Home Builders’ Association (CHBA), wrote, “The Alliance of Canadian Building Officials’ Associations (ACBOA) reported in January 2018 that the profession does not currently have the capacity to properly enforce energy efficiency tiers.”

Resistance to a performance-based NBC are echoed in Task Group feedback submitted by Liz Wynder, technical adviser, code and standards, CHBA.

“CHBA members and staff have serious concerns about the likely consequences of adopting the performance tier PCF 1617 into the NBC.”

Opinion is not unanimous, however. Efficiency Canada, an organization describing itself as, “the national voice for an energy efficient economy,” calls a performance-based approach to enhancing building performance “the best approach.” On its website, it says prescriptive approaches “stifle innovation,” and “are difficult to apply on a national scale, or even a provincial scale, that is comprised of many different climate zones.”

A tiered energy Step Code also results in design and construction cost increases as builders move up the scale towards Net Zero Ready. These costs are ultimately paid for by consumers. Here again, there is disagreement over the amount of increases.

Industry studies in British Columbia cite projected added costs of at least $28,000 for a single detached home built to Step 3 in B.C.’s Step Code, a modest 20 per cent energy efficiency improvement over current code levels. Calculations contained in the NRCanada’s PCF 1617, however, claim increases of only $3,900.

Other concerns resulting from air-tight building envelopes have been raised, such as Interior Air Quality, overheating due to high solar gain windows, and the risk of soil gases like radon being introduced into homes due to negative interior air pressure. The mechanical solutions available, like sophisticated HVACs, balanced ventilation systems and air conditioning, are not only expensive but also somewhat counter-intuitive to a building code seeking to reduce energy consumption.

British Columbia’s Energy Step Code has been viewed as a panacea at both federal and provincial levels among those looking to encourage reduced energy dependency in new residential housing.   

However, it’s worth noting that the Regional District of Central Kootenay recently decided to postpone their adoption of the B.C. Step Code. Reason? Rising building costs in an industry already experiencing severe upward price pressure.


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