CHBA Final Comments Winter 2024 Public Review

Alterations to Existing Buildings (NBC)

1825 Service Water Heating Systems

What: The proposed change introduces requirements for voluntary replacement of service water heating systems that are within scope of an alteration.

Why: A voluntary alteration to a service water heating system in an existing building represents an opportunity to upgrade the energy performance of the system.

NBC20 Div.B 10.9.36.

Impact to Builders

While introducing new national requirements for renovation is significant, the service water heating requirements will have low Impact, because the proposed requirements represent current practice and require equipment with the lowest market available energy performance.

Support As Is

1826 Fenestration, Doors and Skylights

What: This proposed change requires that the thermal characteristics of fenestration, doors and skylights being replaced within scope of a voluntary alteration are upgraded to base code.

Why: Replacing windows, doors or skylights (or installing new windows in an existing home) as part of a voluntary alteration presents an opportunity to improve their respective energy performance.

NBC20 Div.B 10.9.36.

Impact to Builders

Introducing new national requirements for renovation is significant and the fenestration requirements may have some Impact when it comes to replacing only the glazing. AHJs will likely create a new permit scheme for fenestration and glazing replacement and the evaluation of existing glazing can be difficult.

Support with Modifications

As the host organization of a Netzero Housing Labeling Program, CHBA appreciates the intent to require glazing replacement to maintain high-performance windows for high-performance homes. However, we are concerned with a large administrative burden and uncertainty that this proposed change brings with it, which may exceed the small energy reduction benefit achieved with this change. For example, it is very difficult to evaluate existing glazing in the field - both for renovators and enforcement officials – and some (older) frames may not fit current code required triple-glazed products. We suggest deleting Sentence 2 and adding the intent to the proposed appendix note about glazing replacement as a consideration and recommendation.

In comparing the proposed requirements for Part 10 with those proposed for the NECB, we note that the application of PCF 1857 (NECB) is clearer and includes "new building envelope installed in existing buildings." This clarifies that new portions of building envelope are not additions and that they do not have to comply with prescriptive tiered energy requirements.   We suggest adding this phrase also to the end of Sentence 1) in PCF 1826: "Except for maintenance and repair, and except as provided in Sentences (2) and (3), the energy performance of replacement fenestration, doors or skylights [add] and new fenestration, doors or skylights installed in existing buildings [/add] shall comply with Article 9.36.2.7."

1827 Airtightness Requirements

What: This proposed change requires that the continuity of the air barrier is maintained or restored when a portion or the whole of the existing building envelope is under alteration.

Why: When a voluntary alteration includes upgrades to building envelope assemblies an opportunity exists to improve the airtightness (and reduce the associated loss of energy) in the existing building.

NBC20 Div.B 10.9.36.

Impact to Builders

While introducing new national requirements for renovation is significant, the airtightness requirements may have only low impact as the proposed requirements represent accepted, good and current practice. The possibility of airtightness testing is included and allows seamless compliance for renovations under an incentive program. An extensive explanatory note provides good building science guidance.

Support As Is

1828 HVAC Systems Requirements

What: This proposed change introduces requirements for HVAC systems that apply to existing homes and small buildings under alteration.

Why: To make sure voluntary alterations that include upgrades to existing HVAC systems meet a reasonable energy efficiency performance level.

NBC20 Div.B 10.9.36.

Impact to Builders

Low impact, as the proposed requirements describe current practice and low-cost impact as proposal require only current market-available products. Some exemptions exist to limit the requirements to the exposed/accessible portions of the HVAC system (ducts, plenums). Existing HVAC systems need to be evaluated to be suitable for newly created living spaces.

Support As Is

1829 Above-grade Opaque Walls

What: This proposed change requires that the thermal characteristics of above-grade opaque walls, floors and ceilings being replaced within scope of a voluntary alteration are upgraded to base code.

Why: If the R-value of an existing assembly is less than the current base code, this presents an opportunity to upgrade the energy performance of existing buildings.

NBC20 Div.B 10.9.36.

Impact to Builders

Introducing new national requirements for renovation is significant and the above-grade building envelope requirements need to be carefully read and interpreted to avoid substantial (cost) impact and scope creep. The requirements are meant to apply only to elements where the structure or the framing is exposed (Sentence 3 to 6). Where this is missed or misunderstood, a false interpretation could mean, for example, that all siding replacements would have to add insulation. 

Support with Modifications

We generally support this proposed change, but we find that the intent of only requiring upgrades on assemblies with exposed framing is not made very clear and could be misunderstood leading to costly scope expansions of renovation projects. We suggest a new appendix note stating “The requirements in Sentences 3) to 6) clarify that the requirements apply only to assemblies for which the structure or the framing is exposed. This means, for example, that insulation would not have to be added on every project where only the siding is being replaced. While siding replacement does provide an excellent opportunity to improve the thermal performance, by  adding exterior insulation, for example, the additional depth of the envelope may have a lot of consequences in terms of window and door jamb extension and flashing that would involuntarily increase the extent and the cost of the renovation substantially. As well, adding exterior insulation may result in insufficient clearances to neighbouring lot lines (limiting distance) affecting the permitted unprotected openings of the subject building. “

The application of the building envelope alteration requirements proposed for Part 13 of the NECB (PCF 1857) is consistent with those in the proposed new NBC Part 10 as it states "This Section applies to existing building envelope subjected to alteration...", but in the NECB the phrase "and new building envelope installed in existing buildings." is added which clarifies that new portions of envelope assemblies are not additions or extensions and that these new portions of existing assemblies do not have to comply with potentially applicable prescriptive tiered requirements.

We suggest adding this phrase to Sentence 1) in PCF 1829 :" [...], where above-ground opaque building assemblies are subjected to alteration [add] and where new building envelope assemblies are installed in existing buildings [/add], the effective thermal resistance of the building assembly shall conform to Sentences (3) to (6).

For the Appendix Note A-10.9.36.1.(7) and 10.9.36.2.(7)-2025 (PCF 1850) Improvement of Effective Thermal Resistance, we suggest deleting “100mm (4in.)” and leave the expression as “where adding insulation” because the current wording suggests that “100mm (4in.)” of insulation is some kind of a limit or requirement.

1850 Thermal Characteristics of Building Assemblies Below- Grade or in Contact with the Ground

What: This proposed change provides the requirements for upgrading the insulation values of building assemblies below-grade or in contact with the ground that are subject to alteration.

Why: If the R-value of an existing assembly is less than the current base code, this presents an opportunity to upgrade the energy performance of existing buildings.

NBC20 Div.B 10.9.

Impact to Builders

Introducing new national requirements for renovation is significant and the below-grade building envelope requirements need to be carefully read and interpreted to avoid substantial (cost) impact and scope creep. The requirements are meant to apply only to elements where the structure or the framing is exposed or made accessible (Sentence 3 to 6). Where this is missed, a false interpretation could mean, for example, that any basement flooring renovation would trigger adding under-slab insulation.

Support with Modifications

The application of the building envelope alteration requirements proposed for Part 13 of the NECB (PCF 1857) is consistent with those in Part 10 as it states "This Section applies to existing building envelope subjected to alteration...", but in the NECB the phrase "and new building envelope installed in existing buildings" is added, which clarifies that new portions of envelope assemblies – within the existing assembly (repairing a foundation wall for example) – are not additions or extensions and that these new portions of existing assemblies do not have to comply with potentially applicable prescriptive tiered requirements. We suggest adding this phrase to Sentence 1) in PCF 1850 :" [...], where above-ground opaque building assemblies are subjected to alteration [add] and where new below-ground building envelope assemblies are installed in existing buildings[/add], the effective thermal resistance of the building assembly shall conform to Sentences (3) to (6).

We suggest adding a sentence to the end of Appendix Note A-10.9.36.1.(7) and 10.9.36.2.(7)-2025 (PCF 1850) Improvement of Effective Thermal Resistance, to reflect the following: in “The installation of insulation in older buildings should also consider that heat from the building is used to prevent some foundations and footings from freezing, so insulating foundation walls and basement slabs may remove heat from a foundation.”

Sentence 3 does not trigger adding insulation to the outside of a foundation wall where it is exposed or accessible within the extent of an alteration. This application provides better value from a building science perspective and may be less burdensome than adding exterior insulation to an above-grade wall. We suggest adding “where the exterior surface of the foundation wall is exposed” to the triggers in Sentence 3) to read “3] --)Except as provided in Sentence (7), [add] where the exterior surface of the foundation wall [/add], the stud cavity of an exterior foundation wall or interior surface of an exterior mass foundation wall is exposed or made accessible by the alteration or is within the extent of the alteration, the […]”.

Greenhouse Gas Emissions (NBC & NECB)

2004 Operational GHG Emissions Operational GHG Emissions – Tiered Performance Requirements

What: This proposed change introduces performance requirements in NBC Section 9.36.to minimize greenhouse gas emissions from buildings due to the operation of space and water heating appliances

Why: Codes currently regulate energy use for space conditioning and water heating but not the emissions related to the type or quality of energy sources used for this purpose in buildings and houses.

NBC20 Section 9.36.

Impact to Builders

High Impact - This will impact all code users and will have a larger impact on builders in Provinces and Territories which rely on fossil fuels for electricity generation.

Do Not Support

While many of our comments are modifications to the PCF, we cannot support the PCF in its entirety because it fails to recognize zero-emission, on-site energy production via solar photovoltaics. This presents a hardship for the building industry especially because the installation of on-site, zero-emission energy sources for homes would be in the control of builders and homeowners and would give builders in high-emission-intensity provinces more control, while the intensity of the electricity grid is outside of their control (see item #7).

• We note that Sections 9.36. is getting really long and suggest, for greater clarity and simplicity, moving all GHG requirements under a new Section 9.37. This will facilitate the separate treatment of energy tiers and performance levels and will function similarly to the NECB's new Part 11. It would also facilitate the future introduction of embodied GHG emissions less onerous for code users to follow.
• We also note that "house" is being defined and strongly suggest making this a properly ‘Defined Term’ in Article 1.4.1.2. of Division A and not defining it only for Section 9.36. A universal term like “house” should not be defined for only one section.
• We note that Proposed Sentence 9.36.11.4. is redundant. The performance compliance option is repeated verbatim in the next sentence and the NECB option is already provided in the Application section with proposed Sentence 9.36.1.3.(2)
• We also note that the list of fuel emission factors in Table 9.36.11.6. is incomplete and does not include common (fossil) fuel sources. During the transitional time and for reasons of resilience during power outages in the winter and summer, builders and consumers will have to have the choice to include backup energy sources that are not grid related – for the safety of the occupants. We suggest including all available fuel sources to allow choice and consistency for code users. In particular, we recommend re-introducing the emissions factors for wood presented by NRCan Canmet.
• We note that the problem statement mentions the contributions of space conditioning to the total of all building-related emissions, but the justification does not include how many of these emissions are expected to be reduced considering the requirements only address new construction and considering new homes in provinces with hydro-electric electricity production will not contribute to any further improvement. We suggest adding the expected emission reductions to the justification section to explain why the requirements were developed this way and for future reference.
• An impact analysis associated with technical requirements, which was promised in the objectives PCF (Fall 2023 public review) and in the CBHCC policy position document, was not performed comparing the benefits of the requirements vs. the costs of the requirements. The impact analysis on PCF 2004 makes reference to energy efficiency equipment and not the incremental cost associated with switching energy sources (e.g. from gas to electricity) at each Performance Level. The impact analysis never quantifies the estimated benefit (expected GHG reductions across Canada).  Stakeholders and governments can therefore not establish whether the benefit exceeds the cost for society. The impact analysis provided with PCF 2004 therefore does not only not meet the CBHCC’s guidelines it doesn’t answer the most basic question of cost vs. benefit for such a significant change. We suggest stating the expected benefits from the requirements (by performance level) against the associated incremental cost (by performance level) on a national basis.
• We recognize that the CBHCC gave respective instructions not to include renewable energy sources, but we note that not including any recognition of market-available, site-installed, zero-emission energy sources is a huge omission in a code that introduces requirements for the reduction of GHG emissions - especially in provinces where fossil fuels are used for electricity generation. This is a missed opportunity for what the Ministers’ letter called a “2024 zero emissions code”.
  We reject this rushed technical approach because it creates an uneven playing field where the building industry is being regulated for issues it cannot control (i.e. the emission intensity of the electricity grid). For example, a highly insulated, “all-electric” dwelling in high-emission-intensity provinces (e.g., AB, SK, NS) can only achieve GHG Levels D, E and F, while any less insulated dwelling in low-emission-intensity provinces (e.g. QC, MB, BC) can achieve Performance Levels A, B and C – solely because of the emission factor associated with the provincial electricity grid.  Not including renewables presents a hardship for the building industry especially because the installation of on-site, zero-emission energy sources for homes would be in the control of builders and homeowners and would give builders in high-emission-intensity provinces more control.
  
  We suggest therefore revising PCF 2004 to subtract zero-emission, on-site energy production in the calculation of the emission factor. Typically – for solar PV installations – modeling is performed and the ‘annual energy production’ metric could be used in the equation. This would include solar PV installation and exclude solar thermal installations. The annual energy production (in kwh) would be multiplied by the local electricity emission factor  (in CO₂e/kWh) and would become a term that can be subtracted from the sum of all other energy uses and their associated emission factors before the remaining total is being divided by 1000.  The revised equation is produced below with a definition of AEP₀ provided below while GEF_elec is already defined and can simply be copied:
  Revised Equation: CO2_e_proposed = [ (Sum_ES (E_reg_ES x GEF_ES) – (AEP_0 x GEF_elec) ] / 1000

CO2eproposed=(∑ES(Ereg,ES×GEFES)- (AEP₀×GEFelec))/1000

• AEP₀ = annual energy production of zero-emission, on-site energy production in kwh
• Although we are not experts in emissions calculations, we are concerned that the concept underlying the projected electricity emission factors is not equivalent to the concept underlying the gas emission factors. For example, we note that electricity EFs was not subjected to the negative impact of marginal emission factors and similarly the impact of renewable gas sources were not considered in the gas emission factors. In this context, we also note that the expertise on code committees does not extend to this area of expertise.
  We suggest including an emission factor for renewable gas and considering the impact of marginal electricity emission factors.

1989 Operational Greenhouse Gas Emissions Application of a New Part on Operational Greenhouse Gas Emissions

What: This proposed change introduces a new Part to the NECB (which will contain the provisions for operational greenhouse gas emissions).

Why: If the new part is mentioned up front and properly set up with an application provision, the code will become difficult to interpret and apply. 

NECB20 Div.A 1.3.3.1.

Impact to Builders

No Impact to Part 9

Support with Modifications

We note that the justification and impact analysis statements do not refer to or explain the actual change.

We recommend deleting all wording from the justification statement and simply use the last sentence of the problem statement instead. We also suggest describing in the impact statement that this change does not have any impact and is there only to make the code usable and logically consistent (i.e. that Part 10 needs to be included in the provision for operational GHGs and Part 11 for embodied GHG to avoid confusion and inconsistency. None of this is mentioned anywhere.

2026 Operational Greenhouse Gas Emissions Operational GHG Emissions – Tiered Prescriptive Requirements

What: This proposed change introduces prescriptive requirements in NBC Section 9.36. to minimize excessive emission of operational greenhouse gases.

Why: Codes currently regulate energy use for space conditioning and water heating but not the emissions related to the type or quality of energy sources used for this purpose in buildings and houses.

NBC20 Subsection 9.36.12.

Impact to Builders

High Impact - This will impact all code users and will have a larger impact on builders in Provinces and Territories, which rely on fossil fuels for electricity generation.

Support with Modifications

2003 Operational Greenhouse Gas Emissions Operational GHG Emissions – Tiered Performance Requirements (NECB)

What: This proposed change introduces performance requirements to minimize excessive emission of operational GHG emissions.

Why: The National Model Codes (NMC) do not currently consider the type or quality of energy sources used by buildings and houses, nor do they address or regulate embodied and operational GHG emissions.

NECB20 Part 11

Impact to Builders

Low Impact to Part 9 This will impact all NECB users and will have a larger impact on builders in Provinces and Territories which rely on fossil fuels for electricity generation.

Support with Modifications

see our comments on PCF 2004

2016 Operational Greenhouse Gas Emissions Introducing New Abbreviations for Operational GHG Emissions

What: This proposed change adds abbreviations such as GHG, GJ, kWh and CO2e to the list of symbols and abbreviations in the NBC and NECB

Why: While these abbreviations, such as GHG, GJ, kWh and CO2e, are commonly used in industry, they are not assigned meaning in the NBC and NECB.

NECB20 Div.A 1.4.2.1.(1); NBC20 Div.A 1.4.2.1.(1)

Impact to Builders

No Impact other than clarity and consistency of code documents

Support As Is

NBC Part 9 – Energy Efficiency

1890 Prescriptive Trade- off Path Total Point Targets for Tiers (Points)

What: This proposed change assigns minimum energy conservation points (ECP) for Tiers 3, 4 and 5 in the prescriptive trade-off compliance path.

Why: The current code only has minimum energy conservation points for up to Tier 2.

NBC20 Div.B 9.36.8.2.

Impact to Builders

This will allow builders to comply with the energy efficiency requirements without using the performance path (energy modeling).

Support with Modifications

• The minimum sum of Energy Conservation Points (ECP) for Tier 5 is unrealistic and is too high. CHBA has data from the netzero and netzero-ready homes built recognized by the Net Zero Home Labelling Program (which follows the Energuide procedures) indicating that that true Netzero (NZ) performance is possible when complying with Tier 4. Construction to Tier 5 is three-times more costly than tier 4 construction. CHBA is therefore suggesting adjusting the the Tier 5 ECP targets (as well as the Tier 5 prescriptive package) and the Tier 5 performance improvement target to 60%.
• The higher tiers require more stringent airtightness. Therefore, a prescriptive solution for airtightness needs to be provided for areas where testing is not accessible (rural and remote locations) or affordable. CHBA suggests a new prescriptive provision in Subsection 9.36.6. that permits “A primary air barrier system constructed according to Articles 9.36.2.9 and 9.36.2.10. and a secondary air barrier system application in form of an aerosolized, spray-applied sealant is deemed to achieve a AL-3A/AL-4B.”

1923 Prescriptive Trade- off Path Building Envelope (Points)

What: This proposed change assigns energy conservation points for ceilings below attics, cathedral ceilings and flat roofs, exposed floors and slabs-on grade for the prescriptive trade-off path.

Why: Currently there are no points for the highly-insulated assemblies needed when exceeding Tier 2 targets.

NBC20 Div.B 9.36.8.5. NBC20 Div.B 9.36.8.7.

Impact to Builders

Provides design flexibility to code users who prefer the prescriptive path and want to achieve higher Tiers.

Support with Modifications

We believe there was a missed opportunity by not including ECPs for insulation below floors-on- ground (basement slabs) even if the ECPs are minimal. We recommend an additional energy conservation measure table for insulation below floors-on- ground.

2000 Prescriptive Trade- off Path Oil-fired furnaces (Points)

What: This proposed change assigns energy conservation points to oil-fired furnaces for compliance with the Prescriptive Trade-off Path in Section 9.36.

Why: Currently there are no points given for oil-fire furnaces.

NBC20 Div.B 9.36.8.9.

Impact to Builders

Provide design flexibility to code users who prefer using the prescriptive path and who want to achieve higher Tiers.

Support with Comment

We support this proposed change, which promotes fuel diversity, especially in rural and remote locations. This also assists with resilience and the ability to shelter in place during a power outage.

2001 Prescriptive Trade- off Path Air-Source Heat Pumps (Points)

What: This proposed change assigns energy conservation points to air-source heat pumps for compliance with the Prescriptive Trade-off Path in Section 9.36. It provides a look-up table and a calculation method.

Why: Currently there are no points for these measures when exceeding Tier 1 compliance.

NBC20 Div.B 9.36.8.9.

Impact to Builders

Using heat pumps as an energy conservation measures provides a lot of points. This method provides design flexibility to builders who prefer using the prescriptive path and who want/need to achieve compliance with higher Tiers. The proposed code approach requires good knowledge of heat pump technology and efficiency rating details.

Support As Is

1838 Prescriptive Trade- off Path HRV/ERV and Building Envelope (Points)

What: This proposed change further significantly reduces the energy conservation points given in the 2020 NBC for above-grade and foundation wall insulation levels but increases points for HRVs/ERVs relative to those in the 2020 NBC.

Why: The change aligns the prescriptive points (ECP) with the results that would be achieved when modelling according to the performance path. It also provides more granularity and allows interpolation between values.

NBC20 Div.B 9.36.8.5.; NBC20 Div.B 9.36.8.7. NBC20 Div.B 9.36.8.9.

Impact to Builders

This increases the available Energy Conservation Points (ECP) for HRVs and ERVs for code users and makes the table consistent with other energy conservation measures to specific sensible heat- recovery efficiency (SRE) values rater than to ranges of values, linear interpolation is also permitted. This unfortunately also decreases the available ECPs for Above-Ground Walls and the majority of Foundation Walls. Builders in provinces that are adopting the 2020 NBC now, should be aware that the points for the same constructions will change.

Support with Modifications

• The incremental cost figures in the impact analysis do not include the cost of labour. We suggest including labour cost in the HRV/ERV Table to more accurately reflect real cost to the consumer and how this will potentially affect homeowners.
• The 85% sensible heat-recovery efficiency is restrictive and may limit product availability. Upon further research the HRV used in the impact analysis for 85% SRE appears to be in fact only 84% and would not comply. We recommend replacing the row label “85%” with “>80%”. This would encourage design flexibility and facilitate product availability for these ECPs.

1819 Airtightness Replace ACH metric with NLR metric

What: This proposed change removes ACH50 and replaces it with NLR50 as the regulating airtightness metric in NBC Section 9.36.

Why: It improves compliance for attached housing types, aligns the airtightness requirements in the Tiered Performance Path with the Performance Path, and allows the assumption of 1.17 or 0.89 NLR50 for proposed house modelling without conducting an airtightness test for attached and detached houses, respectively.

NBC20 Div.B 9.36.5.10.; NBC20 Div.B 9.36.5.14.; NBC20 Div.B 9.36.6.4.; NBC20 Div.B 9.36.7.3.

Impact to Builders

NLR is often the more favourable metric for small homes and attached homes, however removing the ACH metric may impact members of the residential construction industry, who use ACH to comply with voluntary energy efficiency incentive programs. ACH may be the more favourable metric for larger or homes with a more complex geometry.

Do Not Support (reason)

While we appreciate the intended simplicity of fewer airtightness metrics, we are aware that some builders use the ACH metric for detached dwellings to comply with incentive programs, where NLR would not comply. In the interest of seamless integration of code and incentive programs, we suggest abandoning this proposed change and leaving ACH and NLR in the code as options. Furthermore, several energy advisors and code users who are on site every day, using these metrics, stressed the importance of leaving the ACH metric in the code, stating that this will cause significant disruptions to builders.

1954 Airtightness Using NLR in Administrative Documents

What: This proposed change modifies the airtightness metric required on drawings and specifications for the proposed house.

Why: It aligns the administrative requirements with the proposed revision to the technical requirements in PCF 1819.

NBC20 Div.C 2.2.8.2.(1)

Impact to Builders

This will reduce options for code users

Do Not Support (reason)

The following is a result of consultation with CHBA members across the country: While we appreciate the intended simplicity of fewer airtightness metrics, we are aware that some builders use the ACH metric for detached dwellings to comply with incentive programs, where NLR would not comply. In the interest of seamless integration of code and incentive programs, we suggest abandoning this proposed change.

1869 Energy Use Intensity Path – Building Performance Target Path (NBC 9.36.)

What: This proposed change introduces a new compliance path based on a “budget” for the energy use intensity of a building.

Why: This change offers an alternative to the current proposed vs. reference house compliance approach that may be more suitable to smaller and more compact homes.

NBC20 Div.B 9.36.1.3; NBC20 Div.B 9.36.5.; NBC20 Div.B 9.36.7.

Impact to Builders

This provides another compliance path and may simplify the performance path process. Builders can get credit for more energy efficient housing forms that reduce envelope area, thereby reducing heat loss and associated energy use. This benefits compact design and stacked units.

Do Not Support (reason)

Although CHBA supports design flexibility and additional options for code users to comply we cannot support the proposed metric as it is too stringent and inadvertently causing non-compliance.

• The metrics currently used in the BC Step Code should be adopted instead which would promote harmonization and avoid having to wait for another code cycle to potentially work though the growing pains of refining this method in the field while builders are trying to comply with it.
• Canada is still largely a space-heating dominated country and solar gains should be included especially since limiting the risk of overheating has been identified as a safety issue elsewhere in code committees.
• There appears to be an editorial mistake as 9.36.8. is currently proposed to be used by the tiered energy use intensity requirements and the tiered prescriptive requirements.
• It would be beneficial to code users to include calculation examples in the appendix.

1830 Tier 5 Prescriptive Requirements Energy Efficiency for Houses (Package)

What: This proposed change provides the prescriptive energy efficiency requirements for compliance with Tier 5 of the Energy Performance Compliance Prescriptive Path. (Tier 5 package)

Why: There is currently no fully prescriptive package solution for anything above Tier 1

NBC20 Div.B 9.36.

Impact to Builders

This will benefit all builders who want to comply with Tier 5 prescriptively.

Support with Modifications

• The prescribed package solution for Tier 5 is unrealistic and is very costly (incremental cost between $20,000 and $60,000 depending on region and construction) – about three-times more costly than tier 4 construction. CHBA has data from the netzero and netzero-ready homes built recognized by the Net Zero Home Labelling Program (which follows the Energuide procedures) indicating that that true Netzero (NZ) performance is possible when complying with Tier 4. CHBA is therefore suggesting adjusting the Tier 5 package, the Tier 5 ECP targets and the Tier 5 performance improvement target to 60%. The high cost of the unoptimized Tier 5 prescriptive measures will make housing affordability even worse as the timing of adopting these requirements will overlap with other costly changes coming in the 2025 codes (such as radon, overheating, lateral loads, etc.).
• To meet the minimum RSI value for walls above grade, code users will have to install a minimum of 3" of continuous insulation, which may require additional and engineering details for code compliance of longer (proprietary) fasteners not currently referenced in code. The CHBA Net Zero labelled homes typically use no more than 2” of exterior continuous insulation. We suggest providing an option that uses not more than 2” of insulation or adjusting the performance targets because netzero performance can be reached without tier 5.
• CHBA is concerned that - once embodied carbon will be included in the 2030 codes, these stringent insulation requirements will need to be revised (based on permitted ‘low-carbon’ insulation materials).
• The tier 5 package requires a very stringent airtightness (1.0 ACH). This makes this method, which currently relies on testing, inaccessible in areas where testing is not available. CHBA suggests reducing the airtightness target to 1.5 ACH (or the equivalent NLR value) and permit a prescriptive solution for airtightness for areas where testing is not accessible (rural and remote locations) or where it is cost-prohibitive. CHBA suggests a new prescriptive provision in Subsection 9.36.6. that permits “A primary air barrier system constructed according to Articles 9.36.2.9 and 9.36.2.10. and a secondary air barrier system application in form of an aerosolized, spray-applied sealant is deemed to achieve an AL-3A/AL-4B (1.5 ACH).”
• CHBA is dismayed that the requirements in this ‘package’ were not cost-optimized. We suggest cost-optimizing the required constructions and adjusting the proposed changes accordingly.

2011 Service Water Heating Equipment Efficiency Table Performance metric for heat pump water heaters

What: This proposed change updates the performance metric for heat pump water heaters from Energy Factor (EF) to Uniform Energy factor (UEF).

Why: Failure to update the Codes (NECB and Section 9.36. of the NBC) to the UEF metric will create issues for Code users and regulators when evaluating equipment performance and conformance with the Codes.

NBC Table 9.36.4.2. 9.36.8.10. NECB Table 6.2.2.1.

Impact to Builders

This change is necessary to align with the updated CAN/CSA-C745 standards and will align with the US department of energy.

Support As Is

NBC Part 9 Radon and Soil Gas Mitigation

1713 Radon and Soil Gas Mitigation Passive Vertical Radon Stack

What: This proposed change adds requirements for radon mitigation by use of a passive vertical radon stack in dwelling units and home-type care occupancies that have a wall, roof or floor assembly in contact with the ground.

Why: Would reduce radon levels in all dwelling units and home-type care occupancies and reduce the risk of lung cancer. No further interventions are required if the passive stack lowers the radon levels to acceptable levels.

NBC20 Div.B 9.13.4.

Impact to Builders

Presents a shift in policy from the current requirements intended to reduce radon ingress and facilitate future mitigation, to promising that radon levels will be lowered prior to occupancy. This shift in policy and technical requirements could have liability implications on builders and trigger home warranty providers to impose new requirements similar to those already in place in Ontario (200 bq/m3 for 7 years).

Builders wishing to apply a different approach other than a passive stack, including an active (with fan) mitigation system or capped side- wall vent, would need to

Do Not Support (reason)

CHBA cannot support this PCF which presents a shift in policy from recognizing that all building envelope requirements in the Code minimize the entry of radon and that radon requirements facilitate future mitigation to reducing actual indoor radon concentration levels prior to occupancy.  This shift in policy would present liability challenges for the residential construction industry by requiring reduction of radon levels prior to occupancy to some undetermined level.

PCF 1713 excludes proven technologies for reducing radon such as completing a capped side-wall radon vent following occupancy, or installing an active mitigation system prior to occupancy, since the only option in this PCF is to install a passive stack.  Therefore, we recommend revising the PCF to continue reducing radon levels and facilitating future mitigation regardless of whether one of the options to facilitate future mitigation is a passive stack.

This would require a complete re-write of PCF 1713 to ensure that proven technologies and techniques currently being used by the residential construction industry can continue to be used.

The residential construction industry requires other options for radon mitigation besides a passive stack for the following reasons:

• Passive stacks will not lower radon levels to acceptable levels in all cases and the PCF does not permit the use of radon mitigation fans prior to occupancy.  e.g. 200 Bq/m³ required by Tarion in Ontario
• Installing or replacing fans in attics after the fact can be very challenging, especially with higher levels of insulation required under the tiered energy-efficiency requirements, and even though the PCF now allows for fans to be installed below attics, many homeowners will not want to have a fan installed in their bedroom etc.  
• In order to install a 4” pipe stack in all homes in contact with the ground, many builders would need to redesign existing home plans at an added cost and make changes to new plans that may not be acceptable to their clients.  2x6 int 
• Adding an extra 4” roof penetration in every house or dwelling unit in the country may result in increased incidences of leaks and water damage.
• In areas with high levels of snow accumulation or potential for forest fires, builders often wish to avoid making additional penetrations through roofs.

Suggested Revisions of PCF 1713:

• Problem: Under the problem statement found on page 1 of 17 of the PCF, it refers to research showing "that the majority of cases of radon-induced lung cancer occur in residents of dwellings that have concentrations of radon lower than 200 Bq/m³3". However, it does not currently cite the research report where this finding was documented.  Given that this statement is the fundamental rationale for this entire PCF, 
• the research report, which supports that statement should be cited and a link to the report included in the PCF.
• the portion of the research should be quoted where the causality of the radon concentration is linked with all the dwelling units a lung cancer patients may have lived in and present clinical evidence that radon was the primary cause for the lung cancer death of that patient rather than the WHO estimate of applying a 10% rule of radon-related lung cancers among all lung cancers. 
• Clause 9.13.4.3(3)(iii): This updated clause states that a Code user can rough-in a future stack and cap it until a fan (depressurization equipment) is installed.  Given that 9.13.4.2 requires a passive stack, this requirement no longer appears to be an option.  
  However, if this was intentional, than a capped side-wall vent should also be an acceptable option and should be included under this clause.
• Clause 9.13.4.4.(1)(a): Referenced clause 7.2.4.3 in the 2019 version of CGSB 149.11 ("The passive stack outlet for the radon reduction system should not be installed in roof valleys or other locations where snow or ice are likely to accumulate.") under 9.13.4.4.(1)(a) of this PCF was found to be problematic by the CGSB Technical Committee and has been updated for the 2024 version of the CGSB standard. However, PCF 1713 refers to the 2019 version which still states that passive stacks should not be installed in locations where snow or ice are "likely to accumulate". This requirement is confusing and open to interpretation, and would impose serious challenges in the field for builders, trades and building officials.  
  We recommend removing the reference to clause 7.2.4.3, or deferring the PCF until CGSB 149.11-2024 is available for referencing. 
• Note A-9.13.4 Soil Gas: The ‘radon exclusion measures’ in this PCF only minimize radon infiltration and cannot completely prevent it. Therefore, we recommend striking "or prevent" from the following statement found in Note A-9.13.4 Soil Gas Control on page 7 of 17:
  "The potential for high levels of radon infiltration is very difficult to evaluate prior to construction and thus a radon problem may only become apparent once the building is completed and occupied. Therefore various sections of Part 9 require the application of certain radon exclusion measures that will minimize or prevent radon infiltration in all dwellings. These measures are
  • low in cost,
  • difficult to retrofit, and
  • desirable for other benefits they provide.”

1993 Radon and Soil Gas Mitigation Sealed Overlapping Seams for Air Barriers on Ground

What: This proposed change requires that air barriers in contact with the ground have overlapping seams that are sealed prior to ballast, whether granular fill or a concrete slab is applied.

Why: Sealing of the seams in the air barrier reduces the probability of soil gas leakage at the overlapping seams, which reduces the probability of soil gases, such as radon, leaking into the occupied space of the building where the health of the occupants could be impacted.

NBC20 Div.B 9.18.6.2., NBC20 Div.B 9.25.3.6.

Impact to Builders

The impact on builders will depend on current industry practice. All overlapping seams in an air barrier below a slab would need to be sealed in addition to the joint at the foundation wall, which is already required under Part 9 of the NBC. However, this change is required in order to minimize radon ingress.  Members were concerned about the lack of evidence of a problem with the currently approved approach.

Do Not Support

The PCF states the current approach of overlapping seams by 300 mm is inadequate but does not include any evidence that sealing joints with flexible sealant would be a better approach.  If NRC for instance has done side-by-side comparisons with the currently approved approach and the proposed approach, this information should be added to the PCF since Code changes should be based on evidence-based analysis especially since the PCF states the previous assumption is incorrect.

The cost estimates of $55-$60 for material and labour to seal the overlapping joints is very low and we wonder if this is an error.  Costing should be based on the cost for professionals to carry out the work.

The section on enforcement implications should be updated to state that building officials would need to spend more time to address this new requirement.

In addition, measures in Part 9 only minimize radon entry, the reference to "or prevent" should therefore be deleted in Note A-9.13.4. Soil Gas Control found on page 7 of 11. “The potential for high levels of radon infiltration is very difficult to evaluate prior to construction and thus a radon problem may only become apparent once the building is completed and occupied. Therefore various sections of Part 9 require the application of certain radon exclusion measures that will minimize or prevent radon infiltration in all dwellings. These measures are

• low in cost,
• difficult to retrofit, and
• desirable for other benefits they provide.”

Accessibility, Adaptability, Visitability (Part 9 & Part 3)

1767 Anthropometrics Slope of Ramps Not Located in Accessible Paths of Travel

What: This proposed change modifies the slopes of ramps that are not located in accessible paths of travel so they are safer to use.

Why: Harmonizes Part 9 with Part 3 requirements, which are based on international best practice for people with limited dexterity.

NBC20 Div.B 3.4.6.7., NBC20 Div.B 9.8.5.4.

Impact to Builders

Public areas of Part 3 residential buildings already need to comply with the 1/12 slope and this is being expanded to include Part 9 residential buildings (public areas). Interior and exterior ramps serving dwelling units are exempt and remain at a 1 in 10 slope.

Remain Silent - No Comment

1771 Accessible Menstrual Product Dispensers: Installation Height

What: This proposed change requires that menstrual product dispensers, where provided in a barrier free washroom, be mounted in an accessible location so that they may be reached from a seated posture.

Why: Menstrual product dispensers are sometimes installed at heights or locations that cannot be reached by someone seated in wheeled mobility aids.

NBC20 Div.B 3.8.2.8., NBC20 Div.B 3.8.3.16.

Impact to Builders

Would apply to barrier-free washrooms located in Part 3 residential buildings.

Remain Silent - No Comment

1880 Expanding the Application of the Accessibility Objective to All Dwelling Units

What: This proposed change removes the exemption for houses from the application of the accessibility objective and creates a framework for technical provisions related to accessibility to be considered for houses.

Why: While the NBC has accessibility requirements for many different types of buildings, it does not currently have any that apply to houses because housing is exempt from requirements (limited application of the accessibility objective). This proposed change makes houses accessible to a larger portion of the population in Canada, especially as population demographics shift.

NBC20 Div.A 2.1.1.2.

Impact to Builders

This PCF essentially opens the door for various accessibility requirements to be applied to all dwelling units including private houses, where up until this point, it has been the choice of the builder or homebuyer to include accessibility features. This change is being made in response to a request from provinces and territories for accessibility requirements to be included in the NBC including requirements for "Visitability" for which they can set the application for. e.g. % of apartments.

Do Not Support

CHBA Public Review Comment for PCFs 1880, 1881, 2028, 1883, 1957

CHBA agrees with the following recommendation included – in bold – in the Accessibility Backgrounder posted for the 2024 Winter Public Review: “These PCFs should be reviewed holistically before providing comments on individual changes, as application requirements cannot function without technical provisions and technical requirements cannot be implemented without application provisions.”

Given that only five of the ten proposed changes that describe the new proposed accessibility requirements for dwelling units were included in the winter public review, we recommend that all ten proposed changes be considered in the spring public review in one package. 

In the meantime, we offer the following feedback received from our members to date on the proposed changes that were included in the winter public review (PCFs 1880, 1881, 2028, 1883, 1957).

It’s impossible to assess the impact of a completely new subject without all PCFs presented in one full package.  Removal of the exemption for houses is a major shift and all potential implications for this proposed approach need to be carefully assessed and resolved.

Industry needs more time to understand the implications including potential implications on builders and (code officials) for the application of the accessibility objective on dwelling units, along with technical requirements proposed for the 2025 NBC, as well as future priorities identified by the Canadian Board for Harmonized Construction Codes such as egressibility.

Industry also needs more time to consult with provincial governments on whether they plan to adopt the requirements and how/where they will apply the requirements to better understand the potential impact in each province for all housing types currently being built.

The term “dwelling unit” needs a careful review when it comes to these requirements and the impacts they may have on all housing forms – free-standing single-family homes are not the only housing form.

A lot of the proposed changes ignore the ‘soft’ cost of a transition to more adaptable and visitable housing, such as redesigning existing homes (especially for wider doors to coincide with access to the home, and entry floor bathrooms), as well as changes to sales and marketing materials

PCF 1881 – This appears to be a dated version of this PCF that was since updated.  The correct version should be made available through the public review process.

PCF 1957 – There is a potential conflict with requirements in the Can. Electrical Codes (distance between receptacles Subrule 26-772 d) iii)) where the low edge of a window at the CE Code required location may conflict with the proposed minimum heights in PCF 1957. 

PCF 1883 – Requiring wider entrance doors in all housing forms would create situations where a mobility device may never be able to reach the entrance, or the home itself without elevator (e.g. walk-up units, narrow lots on sloped sites without space for ramps).  A requirement for wider doors in certain housing types could also result in potential land-use conflicts (causing a need for by-law changes), or the need for more land. Many housing types in Canada are optimized for space and a larger entrance door would have many more implications beyond the minimal cost increase noted in the PCF, such as land-use conflicts as mentioned above and the need for more land.

2028 Expanding Accessibility Requirements to Dwelling Units

What: This proposed change removes the exemption for houses from the application of the accessibility objective in Division A of the NBC. This would create a framework for technical provisions related to accessibility to be considered for houses.

Why: While the NBC has accessibility requirements for many different types of buildings, it does not currently have any that apply to houses because these buildings are exempted from requirements based on the application of the accessibility objective. This proposed change makes houses accessible to a larger portion of the population in Canada, especially as population demographics shift.

NBC20 Div.B 3.8.1.

Impact to Builders

These changes will potentially have significant impact.

Do Not Support

CHBA Public Review Comment for PCFs 1880, 1881, 2028, 1883, 1957

CHBA agrees with the following recommendation included – in bold – in the Accessibility Backgrounder posted for the 2024 Winter Public Review: “These PCFs should be reviewed holistically before providing comments on individual changes, as application requirements cannot function without technical provisions and technical requirements cannot be implemented without application provisions.”

Given that only five of the ten proposed changes that describe the new proposed accessibility requirements for dwelling units were included in the winter public review, we recommend that all ten proposed changes be considered in the spring public review in one package. 

In the meantime, we offer the following feedback received from our members to date on the proposed changes that were included in the winter public review (PCFs 1880, 1881, 2028, 1883, 1957).

It’s impossible to assess the impact of a completely new subject without all PCFs presented in one full package.  Removal of the exemption for houses is a major shift and all potential implications for this proposed approach need to be carefully assessed and resolved.

Industry needs more time to understand the implications including potential implications on builders and (code officials) for the application of the accessibility objective on dwelling units, along with technical requirements proposed for the 2025 NBC, as well as future priorities identified by the Canadian Board for Harmonized Construction Codes such as egressibility.

Industry also needs more time to consult with provincial governments on whether they plan to adopt the requirements and how/where they will apply the requirements to better understand the potential impact in each province for all housing types currently being built.

The term “dwelling unit” needs a careful review when it comes to these requirements and the impacts they may have on all housing forms – free-standing single-family homes are not the only housing form.

A lot of the proposed changes ignore the ‘soft’ cost of a transition to more adaptable and visitable housing, such as redesigning existing homes (especially for wider doors to coincide with access to the home, and entry floor bathrooms), as well as changes to sales and marketing materials

PCF 1881 – This appears to be a dated version of this PCF that was since updated.  The correct version should be made available through the public review process.

PCF 1957 – There is a potential conflict with requirements in the Can. Electrical Codes (distance between receptacles Subrule 26-772 d) iii)) where the low edge of a window at the CE Code required location may conflict with the proposed minimum heights in PCF 1957. 

PCF 1883 – Requiring wider entrance doors in all housing forms would create situations where a mobility device may never be able to reach the entrance, or the home itself without elevator (e.g. walk-up units, narrow lots on sloped sites without space for ramps).  A requirement for wider doors in certain housing types could also result in potential land-use conflicts (causing a need for by-law changes), or the need for more land. Many housing types in Canada are optimized for space and a larger entrance door would have many more implications beyond the minimal cost increase noted in the PCF, such as land-use conflicts as mentioned above and the need for more land.

1881 Application of Accessibility Requirements

What: This proposed change revises the application of Section 3.8. by exempting dwelling units from the accessibility requirements.

Why: The proposed change modifies the framework in Section 3.8. to:

• alter the exemption in Clause 3.8.2.1.(1)(a) to allow Section 3.8. to apply to all types of dwelling units,
• create new Subsections that consolidate technical requirements for the adaptability  and visitability of dwelling units (Subsections 3.8.4. and 3.8.5., respectively), and
• define the application of new Subsections 3.8.4. and 3.8.5 to make it clear which proposed requirements apply to each dwelling type. NBC20 Div.B 3.8.2. NBC20 Div.B 3.8. Industry will need to comply with various new minimum requirements for accessibility, adaptability and visitability once this exemption is removed from Section 3.8 Adaptability requirements will apply to all dwelling types, while application of requirements for Visitability will be determined by federal, provincial and territorial regulations or municipal bylaws.

Do Not Support

CHBA Public Review Comment for PCFs 1880, 1881, 2028, 1883, 1957

CHBA agrees with the following recommendation included – in bold – in the Accessibility Backgrounder posted for the 2024 Winter Public Review: “These PCFs should be reviewed holistically before providing comments on individual changes, as application requirements cannot function without technical provisions and technical requirements cannot be implemented without application provisions.”

Given that only five of the ten proposed changes that describe the new proposed accessibility requirements for dwelling units were included in the winter public review, we recommend that all ten proposed changes be considered in the spring public review in one package. 

In the meantime, we offer the following feedback received from our members to date on the proposed changes that were included in the winter public review (PCFs 1880, 1881, 2028, 1883, 1957).

It’s impossible to assess the impact of a completely new subject without all PCFs presented in one full package.  Removal of the exemption for houses is a major shift and all potential implications for this proposed approach need to be carefully assessed and resolved.

Industry needs more time to understand the implications including potential implications on builders and (code officials) for the application of the accessibility objective on dwelling units, along with technical requirements proposed for the 2025 NBC, as well as future priorities identified by the Canadian Board for Harmonized Construction Codes such as egressibility.

Industry also needs more time to consult with provincial governments on whether they plan to adopt the requirements and how/where they will apply the requirements to better understand the potential impact in each province for all housing types currently being built.

The term “dwelling unit” needs a careful review when it comes to these requirements and the impacts they may have on all housing forms – free-standing single-family homes are not the only housing form.

A lot of the proposed changes ignore the ‘soft’ cost of a transition to more adaptable and visitable housing, such as redesigning existing homes (especially for wider doors to coincide with access to the home, and entry floor bathrooms), as well as changes to sales and marketing materials

PCF 1881 – This appears to be a dated version of this PCF that was since updated.  The correct version should be made available through the public review process.

PCF 1957 – There is a potential conflict with requirements in the Can. Electrical Codes (distance between receptacles Subrule 26-772 d) iii)) where the low edge of a window at the CE Code required location may conflict with the proposed minimum heights in PCF 1957. 

PCF 1883 – Requiring wider entrance doors in all housing forms would create situations where a mobility device may never be able to reach the entrance, or the home itself without elevator (e.g. walk-up units, narrow lots on sloped sites without space for ramps).  A requirement for wider doors in certain housing types could also result in potential land-use conflicts (causing a need for by-law changes), or the need for more land. Many housing types in Canada are optimized for space and a larger entrance door would have many more implications beyond the minimal cost increase noted in the PCF, such as land-use conflicts as mentioned above and the need for more land.

1883 Adaptable Dwelling Entrance

What: This proposed change increases the clear width of an entrance to a dwelling unit to accommodate the use of mobility devices. This proposed change introduces a new requirement that every dwelling unit have at least one entrance with a minimum clear width of 850 mm when the door is in the open position.

Why: The current minimum width requirements in the NBC do not permit 10% of modern wheelchairs to enter or exit dwelling units. By requiring at least one entrance that provides a clear width of 850 mm (achievable using a standard 915 mm door opened to approximately 100 to 110 degrees), this proposed change would permit approximately 99% of modern wheelchairs to pass through.

NBC20 Div.B 3.8.

Impact to Builders

In cases where builders are installing 810 mm entrance doors, they would need to install at least one that is 915 mm doors that can be opened 100 to 110 degrees. According to the impact analysis, the cost difference is $100 for a steel door and no difference in cost for fiberglass doors. This may present a design challenge in smaller homes.

Do Not Support

CHBA Public Review Comment for PCFs 1880, 1881, 2028, 1883, 1957

CHBA agrees with the following recommendation included – in bold – in the Accessibility Backgrounder posted for the 2024 Winter Public Review: “These PCFs should be reviewed holistically before providing comments on individual changes, as application requirements cannot function without technical provisions and technical requirements cannot be implemented without application provisions.”

Given that only five of the ten proposed changes that describe the new proposed accessibility requirements for dwelling units were included in the winter public review, we recommend that all ten proposed changes be considered in the spring public review in one package. 

In the meantime, we offer the following feedback received from our members to date on the proposed changes that were included in the winter public review (PCFs 1880, 1881, 2028, 1883, 1957).

It’s impossible to assess the impact of a completely new subject without all PCFs presented in one full package.  Removal of the exemption for houses is a major shift and all potential implications for this proposed approach need to be carefully assessed and resolved.

Industry needs more time to understand the implications including potential implications on builders and (code officials) for the application of the accessibility objective on dwelling units, along with technical requirements proposed for the 2025 NBC, as well as future priorities identified by the Canadian Board for Harmonized Construction Codes such as egressibility.

Industry also needs more time to consult with provincial governments on whether they plan to adopt the requirements and how/where they will apply the requirements to better understand the potential impact in each province for all housing types currently being built.

The term “dwelling unit” needs a careful review when it comes to these requirements and the impacts they may have on all housing forms – free-standing single-family homes are not the only housing form.

A lot of the proposed changes ignore the ‘soft’ cost of a transition to more adaptable and visitable housing, such as redesigning existing homes (especially for wider doors to coincide with access to the home, and entry floor bathrooms), as well as changes to sales and marketing materials

PCF 1881 – This appears to be a dated version of this PCF that was since updated.  The correct version should be made available through the public review process.

PCF 1957 – There is a potential conflict with requirements in the Can. Electrical Codes (distance between receptacles Subrule 26-772 d) iii)) where the low edge of a window at the CE Code required location may conflict with the proposed minimum heights in PCF 1957. 

PCF 1883 – Requiring wider entrance doors in all housing forms would create situations where a mobility device may never be able to reach the entrance, or the home itself without elevator (e.g. walk-up units, narrow lots on sloped sites without space for ramps).  A requirement for wider doors in certain housing types could also result in potential land-use conflicts (causing a need for by-law changes), or the need for more land. Many housing types in Canada are optimized for space and a larger entrance door would have many more implications beyond the minimal cost increase noted in the PCF, such as land-use conflicts as mentioned above and the need for more land.

1957 Reachable Controls in Dwelling Units

What: Constrains the installation location of certain types of controls (e.g., light switches, electrical outlets and regularly operated components of security systems) in a dwelling unit to be within a height range of 400 mm to 1 200 mm above the finished floor or ground surface. Where controls are to be installed in inside corners of a room, this proposed change would require them to be located at least 300 mm from the inside corner.

Why: People using wheelchairs or walkers may find it difficult to reach operating controls and electrical receptacles.

NBC20 Div.B 3.8.

Impact to Builders

These new proposed requirements are intended to apply to all dwelling units. Places limits on where controls and electrical receptacles intended for regular use can be installed. Feedback required on whether the restrictions on commonly used controls and outlets would pose a problem to builders.

Do Not Support

CHBA Public Review Comment for PCFs 1880, 1881, 2028, 1883, 1957

CHBA agrees with the following recommendation included – in bold – in the Accessibility Backgrounder posted for the 2024 Winter Public Review: “These PCFs should be reviewed holistically before providing comments on individual changes, as application requirements cannot function without technical provisions and technical requirements cannot be implemented without application provisions.”

Given that only five of the ten proposed changes that describe the new proposed accessibility requirements for dwelling units were included in the winter public review, we recommend that all ten proposed changes be considered in the spring public review in one package. 

In the meantime, we offer the following feedback received from our members to date on the proposed changes that were included in the winter public review (PCFs 1880, 1881, 2028, 1883, 1957).

It’s impossible to assess the impact of a completely new subject without all PCFs presented in one full package.  Removal of the exemption for houses is a major shift and all potential implications for this proposed approach need to be carefully assessed and resolved.

Industry needs more time to understand the implications including potential implications on builders and (code officials) for the application of the accessibility objective on dwelling units, along with technical requirements proposed for the 2025 NBC, as well as future priorities identified by the Canadian Board for Harmonized Construction Codes such as egressibility.

Industry also needs more time to consult with provincial governments on whether they plan to adopt the requirements and how/where they will apply the requirements to better understand the potential impact in each province for all housing types currently being built.

The term “dwelling unit” needs a careful review when it comes to these requirements and the impacts they may have on all housing forms – free-standing single-family homes are not the only housing form.

A lot of the proposed changes ignore the ‘soft’ cost of a transition to more adaptable and visitable housing, such as redesigning existing homes (especially for wider doors to coincide with access to the home, and entry floor bathrooms), as well as changes to sales and marketing materials

PCF 1881 – This appears to be a dated version of this PCF that was since updated.  The correct version should be made available through the public review process.

PCF 1957 – There is a potential conflict with requirements in the Can. Electrical Codes (distance between receptacles Subrule 26-772 d) iii)) where the low edge of a window at the CE Code required location may conflict with the proposed minimum heights in PCF 1957. 

PCF 1883 – Requiring wider entrance doors in all housing forms would create situations where a mobility device may never be able to reach the entrance, or the home itself without elevator (e.g. walk-up units, narrow lots on sloped sites without space for ramps).  A requirement for wider doors in certain housing types could also result in potential land-use conflicts (causing a need for by-law changes), or the need for more land. Many housing types in Canada are optimized for space and a larger entrance door would have many more implications beyond the minimal cost increase noted in the PCF, such as land-use conflicts as mentioned above and the need for more land.

Part 9 – Standards Updates

1845 Introduce Standards Related to Gypsum Board in Article 9.29.5.2.

What: This proposed change adds 2 existing referenced standards as interior finish to Article 9.29.5.2. of Division B of the NBC: ASTM C1177/C1177M, “Standard Specification for Glass Mat Gypsum Substrate for Use as Sheathing" and ASTM C1658/C1658M, “Standard Specification for Glass Mat Gypsum Panels”.

Why: This proposed change allows use of Type X gypsum board with glass mat facer to be used as interior finish in Article 9.29.5.2. in high moist environment where paper-faced product is not appropriate.

NBC20 Div.B 9.29.5.2.

Impact to Builders

Provides builders with the option of installing Type X gypsum board with a glass mat substrate instead of a paper-faced board in moist environments.

Support with Comment

CHBA supports this PCF which provides builders with the option of installing Type X gypsum board with a glass mat substrate in moist environments.

1846 Introduction of References to Standards Related to Gypsum Board to Sentence D-1.5.1.(2)

What: This proposed change introduces references to three standards that are already referenced elsewhere in the NBC to Sentence D-1.5.1.(2), ASTM C1177/C1177M, “Standard Specification for Glass Mat Gypsum Substrate for Use as Sheathing,” ASTM C1178/C1178M, “Standard Specification for Coated Glass Mat Water-Resistant Gypsum Backing Panel,” and ASTM C1658/C1658M, “Standard Specification for Glass Mat Gypsum Panels.”

Why: These three standards are already referenced elsewhere in the NBC 2020, and referencing them in Sentence D-1.5.1.(2) provides Code users more clarity.

NBC20 Div.B Appendix D

Impact to Builders

This would allow for Type X gypsum board with a glass mat to be considered under the evaluation process defined under Appendix D to determine the fire resistance rating.

Support As Is

1467 Introduction of a New Standard for Asphalt Core Boards

What: This proposed change introduces CSA A123.25:18, “Asphalt core boards used in roofing,” into Table 9.26.2.1.-B.

Why: According to the PCF, there have been membrane failures due to problems with asphalt code board subtrates.

NBC20 Div.B 9.26.2.1.

Impact to Builders

Builders using asphalt core boards on flat roofs would need to ensure that the product complies with the CSA standard.  As noted in the PCF, small manufacturers may not be able to afford the costs for product certification, and this change could therefore impact product supply in some regions.

Support with Modifications

While it's noted in the problem statement that the lack of requirements leads to poor performance of asphalt core boards currently in the market, there is no evidence included in the PCF. Given that this new requirement would pose a hardship on small product manufacturers, the PCF should include some evidence of problems being encountered with asphalt core board substrates currently in the marketplace. Also, the impact analysis states this new requirement will reduce the workload for building officials. How so? Is the certified product stamped? Surely if they need to follow-up with product testers, as noted in the PCF, this would increase their workload and this should be corrected in the PCF. We also suggest clarifying the rationale sections for the PCF.

1964 Spray-Applied Polyurethane Insulation – Introduction of References to New Material and Installation Standards for Light Density, Open Cell Spray-applied Polyurethane Foam

What: This proposed change introduces references to CAN/ULC-S712.1:2021, "Standard for Thermal Insulation – Light Density, Open Cell Spray Applied Semi-Rigid Polyurethane Foam – Material Specification," and CAN/ULC-S712.2:2020, "Standard for Thermal Insulation – Light Density, Open Cell Spray Applied Semi-Rigid Polyurethane Foam –Installation," in Part 9 of the NBC.

Why: The current practice of using light-density, open- cell, spray-applied, semi-rigid polyurethane foam in Canada is not governed by minimum requirements in the NBC. Therefore, it is very difficult for building officials to enforce minimum performance requirements, which has led to inconsistent design and construction. Therefore, there is a need to introduce references to standards in Part 9 of the NBC that provide the minimum material and installation requirements for light-density, open-cell, spray applied, semi-rigid polyurethane foam.

NBC20 Div.B 9.25.2.2., NBC20 Div.B 9.25.2.5 .

Impact to Builders

Open cell spray-applied foam will need to be installed by trained and company certified installers. According to the impact analysis, there are currently four companies in Canada offering open- cell spray applied polyurethane foam and three site quality assurance program providers that can certify these companies programs. These requirements already exist under Part 9 and Part 3 of the NBC for spray-applied closed-cell foam.

Support As Is

Part 9 – Other Changes

1951 Potential Consequences of High Performance Homes Continuity of Insulation

What: This proposed change lowers the insulation requirements for rough opening gaps around windows and doors, excluding the sill.

Why: The continuity of the air barrier and the provision of adequate drainage provides a greater impact on energy performance than does the amount of insulation or the effective thermal resistance (RSI) value of the assembly. Therefore, the gap between the window or door and the supporting structure should be drainable and the rough opening should have a sloped sill or back dam to facilitate water drainage to the exterior of the building envelope. To facilitate positive drainage at the sill as proposed under PCF 1950, to permit a relaxation to the requirements regarding continuity of insulation and minimum effective thermal resistance for the rough opening gap around windows and doors.

NBC20 Div.B 9.36.2.5.

Impact to Builders

Industry would need to move from fully insulating the rough stud openings for doors and windows on all four sides, to insulating the interior face of the header and jambs to a minimum of .56 RSI (R-3)and maintaining the air barrier at the sill location with either little or no insulation to allow for drainage. Reducing the amount of low expansion spray foam insulation may result in additional air leakage at the RSOs.

Do Not Support (reason)

Given that PCF 1951 is a complimentary PCF for PCF 1950 it should only move forward, if and when, PCF 1950 moves forward with it. Achieving continuity of the airbarrier at door and window rough openings without fully insulating the rough opening in order to allow for drainage is a major shift for installation of doors and windows in many parts of the country and will require education and training of installers to ensure there are no negative consequences. This should be reflected in the impact analysis which currently states there would be no change in practice.

It is not clear whether the RSI requirement that applies to the header and jambs is consistent with NRC's 2010 research referenced in the PCF. We note that it states on page 11 that "Only the use of spray foam insulation provided a seal to the perimeter thereby avoiding cooling of the window profile." The information found in the impact analysis stating this will not result in "changes to current installation practices" is also inaccurate and should be updated. We suggest confirming the RSI value and clarifying the provision.

Part 3 & Part 9 – Fire and Stair Safety

1772 Handrails Minimum Width Between Handrails

What: This proposed change clarifies the minimum width of stairs or ramps where an intermediate handrail is required with corrections in language and with new diagrams.

Why: There has been confusion with the intent of the requirements and the changes are intended to help explain the requirements and help avoid misinterpretations.

NBC20 Div.B 3.4.6.5.

Impact to Builders

Where handrails are installed in public areas of Part 3 residential buildings, these changes would impact railing design - likely positively - since they are clarifying the requirements.

Support As Is

1969 Building Fire Safety Part 9 Reference to New Standard for Testing of Protective Coverings over Foamed Plastic Insulation

What: This proposed change introduces Clause 9.10.17.10.(1)(d), and its cross-reference to Part 3, to maintain harmonization between proposed changes to provisions in Parts 3 and 9 for the protection of foamed plastics.

Why: As stated in PCF 1967, the proposed change in Part 3 introduces a reference to

CAN/ULC-S145 on the basis that it offers a suitable performance-based approach to limit the contribution of foamed plastic insulation to early fire growth. PCF 1967 provides Code users including manufacturers, designers, regulators and AHJs) with an additional compliance path that outlines an acceptable level of performance for protective covering products to be considered acceptable solutions in assemblies, which facilitates enforcement.

NBC20 Div.B 9.10.17.10.

Impact to Builders

According to the foam plastics industry, the original code change request was supported by CCMC testing carried out on spray-applied foam insulation and the industry has yet to review test data for other foam insulation products and is therefore concerned about potential liability and unintended consequences. They are recommending that the proposed requirements be limited in scope to "thermosetting, spray- applied, foam plastic insulation and that further study be carried out on various foam plastic materials.

Support with Modifications

CHBA supports the recommendation made by the Chemistry Industry Association of Canada to limit the scope of PCF 1967 to thermosetting, spray-applied, foam plastic insulation. We also support the recommendation for further study the application of the product on other foam products.

1967 Building Fire Safety New Standard for Testing of Protective Coverings over Foamed Plastic Insulation

What: This proposed change introduces references to CAN/ULC-S145:2018, "Standard Method of Test for the Evaluation of Protective Coverings for Foamed Plastic Insulation – Full-Scale Room Test."

Why: As more options for protective coverings enter the market, it becomes more critical to provide manufacturers, regulators and Code users with an additional compliance path that specifies a minimum level of performance for these products to be considered acceptable solutions where incorporated in a tested assembly. Not including these specifications in the Code presents the danger of leaving the door open for the definition of the acceptable minimum level of performance by others and for protective covering products to be applied inappropriately in practice.

NBC20 Div.B 3.1.4.2.(1 ), NBC20 Div.B 3.1.5.15.

Impact to Builders

According to the foam plastics industry, the original code change request was supported by CCMC testing carried out on spray-applied foam insulation and the industry has yet to review test data for other foam insulation products and is therefore concerned about potential liability and unintended consequences. They are recommending that the proposed requirements be limited in scope to "thermosetting, spray- applied, foam plastic insulation and that further study be carried out on various foam plastic materials.

Support with Modifications

CHBA supports the recommendation made by the Chemistry Industry Association of Canada to limit the scope of PCF 1967 to thermosetting, spray-applied, foam plastic insulation. We also support the recommendation for further study on other foam products.

Part 3 – Sprinkler Requirements 

Automatic Sprinkler System (19 PCFs)

What: This proposed change is one of a series of proposed changes that standardize the terminology related to sprinklers in the NBC. The term "sprinklered" is being proposed as a replacement for 11 different phrases currently used in the NFC to describe where sprinklers are mandated, and 8 different phrases to describe where they are not required.

Why: Not standardizing this terminology could potentially cause confusion among architects and designers as to where sprinklers are mandated. Revising the Code wording to use the defined term “sprinklered” would introduce consistency as well as eliminate any potential confusion.

NBC20 Div.B 3.2.5.13.(3)

Impact to Builders

Provides clarity on where sprinkler related requirements apply. Positive change that should not result in any additional requirements or costs.

Remain Silent - No Comment

• 1910 Standardization of Terminology in NBC Sprinkler Requirements
• 1912 Standardization of Terminology in NBC Sprinkler Requirements
• 1915 Standardization of Terminology in NBC Sprinkler Requirements
• 1916 Standardization of Terminology in NBC Sprinkler Requirements
• 1917 Standardization of Terminology in NBC Sprinkler Requirements
• 1920 Standardization of Terminology in NBC Sprinkler Requirements
• 1921 Standardization of Terminology in NBC Sprinkler Requirements
• 1922 Standardization of Terminology in NBC Sprinkler Requirements
• 1924 Standardization of Terminology in NBC Sprinkler Requirements
• 1925 Standardization of Terminology in NBC Sprinkler Requirements
• 1926 Standardization of Terminology in NBC Sprinkler Requirements
• 1927 Standardization of Terminology in NBC Sprinkler Requirements
• 1928 Standardization of Terminology in NBC Sprinkler Requirements
• 1929 Standardization of Terminology in NBC Sprinkler Requirements
• 1930 Standardization of Terminology in NBC Sprinkler Requirements
• 1931 Standardization of Terminology in NBC Sprinkler Requirements
• 1932 Standardization of Terminology in NBC Sprinkler Requirements
• 1933 Standardization of Terminology in NBC Sprinkler Requirements
• 1934 Standardization of Terminology in NBC Sprinkler Requirements

Part 4 – Structural Design & Appendix C

1895 Earthquake Design Datum for the Determination of N̅ 60 and s̅u in Article 4.1.8.1.

What: The proposed change revises the determination of two seismic metrics in Article 4.1.8.1. to make it consistent with the rest of Subsection 4.1.8.

Why: This inconsistency is a source of confusion and could lead to the incorrect and inadequate design of buildings.

NBC20 Div.B 4.1.8.1.

Impact to Builders

No Impact to Part 9 construction. This is a clarification in Subsection 4.1.8.

Remain Silent - No Comment

1896 Earthquake Design Clarification of the Scope of Article 4.1.8.4.

What: This proposed change adds an explanatory Note clarifying that Article 4.1.8.4. may not be suitable for sites with certain ground profiles.

Why: The models used to generate the estimated seismic hazard values for the NBC are based on generic ground profiles. These provisions should not be used for sites with ground profiles that fall outside of the generic assumptions, for example, sites near active faults, sloping bedrock sites, or sites with ground profiles that are highly variable across the building footprint.

NBC20 Div.B 4.1.8.4.

Impact to Builders

No Impact to Part 9 construction. This is a clarification in Subsection 4.1.8.

Remain Silent - No Comment

1897 Earthquake Design Clarification of the Permission for Liquefiable Soils

What: The proposed change clarifies an exemption and adds an explanatory Note on Sentence 4.1.8.4.(5) for short-period (i.e. low-rise) structures built on liquefiable soils.

Why: The NBC provides a relaxation for the determination of spectral acceleration values for short-period (low-rise) structures on liquefiable soils. However, this relaxation could be incorrectly interpreted to bypass the requirement for checking the potential for liquefaction and its effect on the structure.

NBC20 Div.B 4.1.8.4.

Impact to Builders

Low Impact. Although these requirements and relaxations apply to low- rise structures, taking away from the relaxation doesn't seem to affect Part 9, except where Part 4 for seismic design is necessary.

Remain Silent - No Comment

1898 Earthquake Design Revisions to Article 4.1.8.1. (Simplified Method)

What: The proposed change adjusts the triggers permitting the use of the simplified method in Article 4.1.8.1. for seismic design and modifies the approach for determining the design spectral acceleration.

Why: The reduction in the number of localities where the simplified method can be used presents a hardship for Code users who have relied on this method since it was introduced in the NBC 2015 to satisfy seismic design requirements in localities where the seismic hazard is low.

NBC20 Div.B 4.1.8.1.

Impact to Builders

Low impact for residential builders following Part 9, but possible positive impact where structural designers are involved in using NBC Part 4 in low seismic areas.

Remain Silent - No Comment

1899 Earthquake Design Clarification of the Performance Requirements for Post-disaster Buildings, High Importance Category Buildings, and a Subset of Normal Importance Category Buildings

What: This proposed change clarifies the additional performance requirements in Article 4.1.8.23. for post- disaster buildings, High Importance Category buildings, and a subset of Normal Importance Category buildings.

Why: A lack of clarity in some of the existing requirements of Article 4.1.8.23. of Division B of the NBC could result in difficulties for designers complying with the requirements and for enforcement staff checking compliance with the requirements.

NBC20 Div.B 4.1.8.23.

Impact to Builders

No Impact to Part 9 construction. This is a clarification in Subsection 4.1.8. about post-disaster buildings and high importance category buildings (hospitals, etc)

Remain Silent - No Comment

1901 Earthquake Design Modification to the Requirements for Determining Specified Lateral Earthquake Force

What: This proposed change modifies the formula for the specified lateral earthquake force, Vp, in Article 4.1.8.18.

Why: The current formula for Vp, provides incorrect results and, in some cases, unconservative design forces in other cases, over-conservative results.

NBC20 Div.B 4.1.8.18.

Impact to Builders

No Impact to Part 9 construction. This is a correction in Subsection 4.1.8. that makes Part 4 design calculations more precise.

Remain Silent - No Comment

1976 Earthquake Design Updating the Seismic Hazard in Northwestern Canada

What: This proposed change refers to reduced seismic hazard values for parts of Northwestern Canada. It also implements the editorial changes required to reference 2025 National Building Code of Canada Seismic Hazard Tool.

Why: These seismic hazard values are larger than intended and may result in unintendedly higher costs of construction. The values are not the code but in one of the modeling tools referenced. NBC20 Div.B 1.1.3.1. Low Impact impacts only Part 4 structural design in the North.

Impact to Builders

Positive impact as resulting seismic hazard values are lower

Support As Is

1996 Earthquake Load and Effects -General Requirements Clarification of Provisions for Structural and Non- Structural Elements not Part of the SFRS

What: The proposed change modifies the existing Code provisions for structural and non-structural elements that are not part of the defined seismic force resisting system (SFRS) of a building.

Why: Ambiguity in the current Code is a source of confusion among Code users, which has led to inconsistent interpretation of the Code.

NBC20 Div.B 4.1.8.3.

Impact to Builders

No Impact or Low impact for residential builders following Part 9, but possible impact where structural designers are involved in using NBC Part 4 for Part 9 buildings.

Remain Silent - No Comment

Part 5 – Building Envelope

1427 Building Envelope - General Replacement of an outdated CGSB standard

What: Replaces CAN/CGSB-1.501-M89, "Method for Permeance of Coated Wallboard," with ASTM D1653- 13, "Standard Test Methods for Water Vapor Transmission of Organic Coating Films," in Part 9 of the NBC.

Why: The CGSB standard has not been updated since its initial publication in 1989 and was withdrawn by the Canadian General Standards Board (CGSB) in October 2011.

NBC20 Div.B 9.13.2.2., NBC20 Div.B 9.25.4.2.

Impact to Builders

Positive Impact. This should impact industry positively because referencing outdated standards often imposes liability to industry (not being able to comply/ non- availability of tested product, etc) as long as the performance of the new standard is equal and products are available in Canada.

Support As Is

National Energy Code of Canada for Buildings

1857 Alterations of the building envelope

What: The proposed change adds requirements defining the application of NECB Part 3 to building envelope subject to alterations.

Why: Alterations provides a good opportunity to upgrade the building envelope assemblies to current base Code requirements. However, work on the building envelope can be costly, and thus, the requirements of Part 3 applicable to alterations have been adapted to balance the opportunity for upgrades with reasonable cost-effectiveness.

NECB20 Div.B 13.3.

Impact to Builders

Low impact to residential industry. The proposed requirements are mainly conceptually consistent with those in Part 9. There are some inconsistencies between the NECB and the Part 9 approach.

Support with Modifications

In comparing the proposed requirements for Part 9 and the NECB we note that the replacement of glazing in the NECB is exempt if the U-value is not worse than the existing glazing and that no requirement exists to upgrade to current requirements. This is inconsistent with the notion for housing and small buildings. This difference is neither explained in the justification nor in the impact analysis section.

We suggest making the NECB consistent with Part 9 (PCF 1826) either by including a requirement to comply with current U-values in the NECB or by exempting glazing replacement in the Part 9 AEB requirements.

1858 Alterations of lighting systems

What: The proposed change states how the NECB Part 4 lighting system requirements apply to alterations.

Why: Voluntary alterations provide a good opportunity to upgrade lighting systems to base Code requirements. However, since renovation works in existing buildings can be more costly than new construction, the lighting requirements of NECB Part 4 have been adapted to maintain an acceptable cost-effectiveness.

NECB20 Div.B 13.4.

Impact to Builders

Low impact to residential builders. There are no consistency issues, since lighting is not addressed in Part 9 energy efficiency requirements.

Remain Silent - No Comment

1859 Alteration of HVAC Systems

What: The proposed change states how NECB Part 5 applies to HVAC systems subject to alterations and to new HVAC systems installed in existing buildings.

Why: Alterations provides a good opportunity to upgrade HVAC systems and equipment and any ancillary components to meet base Code requirements. However, since renovation works in existing buildings can be more costly than new construction, the HVAC requirements have been adapted to maintain an acceptable cost- effectiveness.

NECB20 Div.B 5.1.1.2., NECB20 Div.B 13.5.

Impact to Builders

Low impact to residential builders. The NECB version of the alteration requirements for HVAC is conceptually consistent with that of Part 9 (PCF 1828) but contains more complex systems.

Remain Silent - No Comment

1860 Alteration of Service Water Heating Systems

What: The proposed change states how NECB Part 6 applies to Service Water Heating Systems subject to alterations and to new systems installed in existing buildings.

Why: Alterations provides a good opportunity to upgrade service-water heating systems and equipment and piping to meet base Code requirements. However, since renovation works in existing buildings can be more costly than new construction, the service water heating requirements have been adapted to maintain an acceptable cost-effectiveness.

NECB20 Div.B 13.6.

Impact to Builders

Low impact to residential builders. The NECB version of the alteration requirements for service water heating systems and equipment is conceptually consistent with that of Part 9 (PCF 1825).

Remain Silent - No Comment

1861 Alterations of electrical power systems and motors

What: The proposed change states how the NECB Part 7 electrical power system and motor requirements apply to alterations.

Why: Voluntary alterations provide a good opportunity to upgrade electrical power systems and motors to base Code requirements.

NECB20 Div.B 13.7.

Impact to Builders

Low impact. The Code requirements for transformers and motors reference CSA standards that have not been significantly changed in several years. All equipment available on the market is expected to meet the requirements of the CSA standards. Therefore, this proposed change would not impose an additional burden.

Remain Silent - No Comment

1862 Alterations of the Building envelope (NECB)

What: The proposed change adds administrative requirements related to alterations of the building envelope.

Why: With the introduction of alterations to existing buildings in the NECB 2025, there will be a need for information and calculations related to the extent of alterations.

NECB20 Div.C 1.2.1.1.; NECB20 Div.C 2.2.

Impact to Builders

Low impact.  This is an administrative requirement in Division C about the drawings and documents to be presented for alteration work. The proposed requirements seem to state current practice.

Support with Comment

We note that the SCEE did develop Div C administrative requirements for renovations for the NECB but not for the same requirements in Part 9. If the impact of consistent administrative requirements is indeed as significant as the impact analysis states, why were equivalent proposed changes not created for the NBC AEB 10.9.36. in Division C of the NBC?

1863 Alterations of Lighting Systems (NECB)

What: The proposed change adds adapted administrative requirements or the alterations of lighting systems.

Why: With the introduction of alterations to existing buildings in the NECB 2025, there will be a need for information and calculations related to the extent of alterations.

NECB20 Div.C 2.2.

Impact to Builders

Low impact. This is an administrative requirement in Division C about the drawings and documents to be presented for alteration work. The proposed requirements seem to adapt current reqs to the scope of the alteration.

Support with Comment

We note that the SCEE did develop Div C administrative requirements for renovations for the NECB but not for the same requirements in Part 9. If the impact of consistent administrative requirements is indeed as significant as the impact analysis states, why were equivalent proposed changes not created for the NBC AEB 10.9.36. in Division C of the NBC?

1864 Alterations of HVAC systems (NECB)

What: The proposed change adds adapted administrative requirements related to alterations of HVAC systems.

Why: With the introduction of alterations to existing buildings in the NECB 2025, there will be a need for information and calculations related to the extent of alterations.

NECB20 Div.C 2.2.

Impact to Builders

Low impact. This is an administrative requirement in Division C about the drawings and documents to be presented for alteration work. The proposed requirements seem to adapt current reqs to the scope of the alteration.

Support with Comment

We note that the SCEE did develop Div C administrative requirements for renovations for the NECB but not for the same requirements in Part 9. If the impact of consistent administrative requirements is indeed as significant as the impact analysis states, why were equivalent proposed changes not created for the NBC AEB 10.9.36. in Division C of the NBC?

1865 Alterations of Service water systems (NECB)

What: The proposed change adds adapted administrative requirements related to alterations of service water systems.

Why: With the introduction of alterations to existing buildings in the NECB 2025, there will be a need for information and calculations related to the extent of alterations.

NECB20 Div.C 2.2.

Impact to Builders

Low impact. This is an administrative requirement in Division C about the drawings and documents to be presented for alteration work. The proposed requirements seem to adapt current reqs to the scope of the alteration.

Support with Comment

We note that the SCEE did develop Div C administrative requirements for renovations for the NECB but not for the same requirements in Part 9. If the impact of consistent administrative requirements is indeed as significant as the impact analysis states, why were equivalent proposed changes not created for the NBC AEB 10.9.36. in Division C of the NBC?

1866 Alterations of Electrical power systems and motors (NECB)

What: The proposed change adds administrative requirements related to alterations of Electrical Power Systems and Motors.

Why: With the introduction of alterations to existing buildings in the NECB 2025, there will be a need for information and calculations related to the extent of alterations.

NECB20 Div.C 2.2.

Impact to Builders

Low impact. This is an administrative requirement in Division C about the drawings and documents to be presented for alteration work. The proposed requirements seem to adapt current reqs to the scope of the alteration.

Support with Comment

We note that the SCEE did develop Div C administrative requirements for renovations for the NECB but not for the same requirements in Part 9. If the impact of consistent administrative requirements is indeed as significant as the impact analysis states, CHBA suggests creating the equivalent for the NBC AEB 10.9.36. in Division C of the NBC.

Since there is no PCF for NBC Div C, this modification is suggested here.

1990 Alteration-Defined Terms

What: The proposed change copies the defined term “alteration” from the NBC into the NECB.

Why: The term “alteration” is currently defined in the NBC but not in the NECB.

NECB20 Div.A 1.4.1.2.

Impact to Builders

Should have low impact, but may cause major confusion, since the term alteration is defined using the word 'extension' which is used in Part 9 provisions with the meaning of 'addition'.

Do Not Support (reason)

Consistency and harmonization between different national construction codes is always good and we would support this change, if it didn't cause more confusion. We cannot support this change because the term 'alteration' is proposed to be defined using the word 'extension', which can be understood to mean 'addition', which is also a defined term in the NECB (but not in the NBC). Since the NECB and NBC apply different sets of requirements to alterations and additions respectively, using the word 'extension' leaves the proposed definition ambiguous and unhelpful.

We suggest either

• changing NBC and NECB definitions of 'alteration' without using the word 'extension', or
• adding a new definition to both codes for the term 'extension' that differentiates it from 'addition'
• writing a detailed appendix note in the NBC and NECB about the desired and common interpretation in NECB and NBC of the terms 'alteration', 'extension', and 'addition'.

This modification is critical, because different requirements apply based on these terms in the proposed NBC Part 10 and NECB Part 13 and the current defined term is not unambiguous.

1991 Scope and application of Part 13

What: The proposed changes states the scope and application of Part 13 of the NECB to alterations of existing buildings.

Why: The intent of these 'general' requirements is clarify to which buildings Part 13 applies (application) and to state some defined terms and to explain important principles and performance expectations.

NECB20 Div.B 13.1.; NECB20 Div.B 13.2.

Impact to Builders

Low impact to renovators of Part 9 buildings except for issues of consistency with the NBC equivalent provisions

Support with Modifications

The PCF defines 'replacement', which was also suggested for the NBC, but rejected. CHBA suggests that this in-context definition be converted to proper defined term in NBC and NECB, except that the word 'product in the phrase "[substitution of...] an existing assembly with a similar product" should be replaced with 'product or assembly'. CHBA also suggests adding the missing principles describing the intent of the requirements to be pragmatic, practical and reasonable (see SCEE revisions to PCF 1824). CHBA also notes that the NECB version of this PCF does not use the term "Compliance"

1653 Building Envelope - General Use of the Term "Grade" in the NECB Part 3 Appendix

What: Using the term "ground" instead of "grade" to refer to the finished ground level.

Why: If Code users determine the requirements for the insulation of a building component based on the definition of grade provided in the NBC, which is reproduced in the NECB, this could lead to the installation of thermal insulation that is insufficient to minimize heat loss.

NECB20 Div.B 3.2.3.2.(1)

Impact to Builders

This has a positive impact to the industry, this should reduce confusion.

Support As Is

1962 Building Envelope - General Use of the Term "Grade" in the NECB Part 3 Appendix

What: Clarifies by using “ground” instead of “grade” to refer to the finished ground level.

Why: Using the non-defined term “ground” instead of “grade” to determine the required thermal resistance of a building component will minimize heat loss and better meet the objectives of the NECB.

NECB20 Div.B 3.2.1.1.(1)

Impact to Builders

This has a positive impact to the industry, this should reduce confusion.

Support As Is

1840 Building Envelope - General Use of the Term "Grade" in the NECB Division C

What: Clarifies the documentation required for the building envelope by using “ground” when referring to finished ground level.

Why: If Code users applies the requirements for insulation of a building component based on the definition of grade, it could lead to the installation of thermal insulation that is less than that required to reduce heat transfer losses.

NECB20 Div.C 2.2.2.3.(1)

Impact to Builders

This has a positive impact to the industry; this should reduce confusion.

Support As Is

2009 Climatic Values Climatic Data for Energy Model Calculations

What: This proposed change updates the explanatory Note to refer to recent climatic data.

Why: The current reference to the climatic data in the explanatory Notes NECB Div.B A-8.4.2.3. and NBC Div.B A-9.36.5.5.(1) is outdated.

NECB20 Div.B 8.4.2.3., NBC20 Div.B 9.36.5.5.(1)

Support As Is

1868 Energy Use Intensity Metric Path – Building Performance Target Path (NECB)

What: This proposed change introduces a new compliance path based on the absolute energy performance target of the building.

Why: Failure to provide the Code user with an alternative energy performance path to the proposed vs. reference approach to demonstrate compliance with the performance path of the NECB will limit the options available to the Code user to improve building energy performance to meet the Objective of minimizing excessive use of energy

NECB20 Div.B Part 8. X  (likely a new section)

Impact to Builders

This provides another compliance path for meeting the energy conservation requirements along with existing prescriptive and performance paths.

Support with Modifications

CHBA generally supports design flexibility and more options for code users to comply, but we do find the calculations to comply with the building performance target path to be complicated and recommend providing an example calculation.

CHBA also noted that the equivalent proposed change for housing (PCF1869) seems overly stringent in terms of the geometric and size features of buildings that comply, indicating that the metric itself or the criteria for compliance would need to be reviewed to make PCF 1869 and effective and useful compliance method. We suggest that a similar ‘usefulness and effectiveness’ review be conducted for the NECB EUM compliance path.

National Plumbing Code of Canada

992 Materials and Equipment Standard for Wall-Hung Water Closet

What: This proposed change introduces a reference to a standard for wall carriers for water closets.

Why: This proposed change includes a reference to ASME A112.6.1M-1997, “Floor-Affixed Supports for Off-The-Floor Plumbing Fixtures for Public Use,” a new standard for the performance of wall carriers for water closets. This requirement would address a gap in the National Plumbing Code and prevents the installation of improper supports for water closets. NPC20 Div.B 2.2.2. Would only impact builders installing wall hung water closets where a wall carrier is attached to the floor.

Impact to Builders

For those using uncertified wall carriers, there will likely be a cost increase to use certified wall carriers.

Remain Silent - No Comment

2005 Building Fire Safety Rooftop Enclosures as a Storey for Determining Elevator Car Dimensions

What: This proposed change clarifies whether a rooftop enclosure provided for elevator machinery, a stairway or a service room is intended to be considered as a storey for the purposes of Article 3.5.4.1.

Why: This proposed change would eliminate confusion among Code users and ensure that the requirements are applied and enforced as intended.

NBC20 Div.B 3.5.4.1.

Impact to Builders

Positive impact for Part 3 residential buildings due to clarity and not having to apply elevator space requirements to rooftop enclosures.

Support As Is

1690 Defined Terms Condensate Drainage

What: The proposed change introduces the defined term “condensate drainage system" in the NPC and revises the definitions of the terms "clear-water waste" and “drainage system” to address condensate drainage.

Why: Including the definition of “condensate drainage system” in the NPC would facilitate the inclusion of heating and other systems (e.g. HRVs) within the scope of a plumbing system and support subsequent Code changes to incorporate prescriptive requirements for condensate drains.

NPC20 Div.A 1.4.1.2.

Impact to Builders

It is our understanding that condensate drains for gas-fired furnaces and HRVs are typically installed by HVAC contractors. By including condensate drains within the scope of the plumbing code, it may trigger the need for this work to be carried out by certified plumbers.

Remain Silent - No Comment

1707 Defined Terms Macerating Toilet System

What: This proposed change introduces a definition for “macerating toilet system" to be included under Division A.

Why: Defining the term “macerating toilet system” is required to provide clarity and consistency for users of the National Plumbing Code and to facilitate enforcement for authorities having jurisdiction. NPC20 Div.A 1.4.1.2. No negative impact on the residential construction industry.

Impact to Builders

Provides clarity and consistency for Code users.

Support As Is

1370 Drainage Systems Size of Storm Drainage Pipes

What: This proposed change extends sizing requirements already in place for soil or waste pipes to storm drainage pipes. It proposes to add a Sentence to Article 2.4.9.1. prohibiting storm drainage pipes from draining into smaller-diameter pipes.

Why: Requiring a storm drainage pipe to be of a nominal pipe size (NPS) not less than the NPS of the largest storm drainage pipe that drains into it would limit the probability of flow restrictions that can cause accumulation of sludge and solids, which can lead to drainage system blockages.

NPC20 Div.B 2.4.9.1.

Impact to Builders

Reduced flow restrictions and resulting problems, which would have a positive impact on builders. Designers and plumbers will need to ensure proper sizing of storm drainage pipes.

Remain Silent - No Comment

1692 Drainage Systems Condensate Drainage Systems

What: This proposed change introduces requirements for condensate drainage systems that serve heating, ventilation and air-conditioning systems.

Why: This proposed change would allow existing piping and common practice for small-diameter condensate drainage systems to comply with the NPC. Code users would be able to refer to Code requirements for use of smaller diameter tubes or pipes. The proposed change provides clarity on how to approach condensation, building size and occupancy in multi- or single-appliance systems.

NPC20 Div.B 2.4.1.1., NPC20 Div.B 2.4.2.1., NPC20 Div.B 2.4.2.3., NPC20 Div.B 2.4.3., NPC20 Div.B 2.2.5., NPC20 Div.B 2.4.9., NPC20 Div.B 2.4.5.

Impact to Builders

Pipes and tubing used for condensate drains would need to comply with these new requirements.

Remain Silent - No Comment

1727 Drainage Systems Neutralization Tanks

What: This proposed change removes dilution as an acceptable method for the treatment of corrosive or acid waste to better protect the environment and plumbing infrastructure.

Why: The proposed change would remove dilution as an acceptable means of treating corrosive or acid waste to avoid contradiction with local sewer use bylaws and subsequent confusion for Code users. The change would bring NPC requirements for the treatment of such waste into alignment with those in the Canadian Model Sewer Use Bylaw and better protect plumbing infrastructure and the environment from harsh

chemicals.

NPC20 Div.B 2.4.4.4.

Impact to Builders

No impact on the residential construction industry.

Remain Silent - No Comment

1790 Drainage Systems Emergency Roof Drainage

What: This proposed change clarifies the requirements for storm drainage systems and expands on the use of an emergency overflow as a separate system at critical points in the storm drainage system.

Why: This proposed change would clarify the existing provisions for drainage systems using scuppers or low parapet walls and would also give Code users the additional options of using a completely separate emergency roof drainage system or connecting the emergency roof drains to an oversized main system.

NPC20 Div.B 2.4.6., NPC20 Div.B 2.4.10.4.

Impact to Builders

Provides clarity and options for compliance. Will help ensure proper drainage of flat roofs.

Remain Silent - No Comment

1693 Piping Support for Nominally Horizontal Piping

What: This proposed change introduces horizontal spacing of supports for solid wall PVC plastic pipe.

Why: This proposed change adds a new row to Table 2.3.4.5. to incorporate different pipe sizes and corresponding pipe support spacing for solid wall PVC pipe. The clarity provided in directly linking support spacing to pipe size will allow the cost- effective installation of pipe supports, avoiding unnecessary costs.  This proposed change also adds cellular core PVC to the list of materials requiring a pipe support spacing of 1.2 m. This would help prevent the improper installation of pipe supports for this product, which mitigates the risk of pipe damage and degradation. Furthermore, this proposed change aligns Table 2.3.4.5. with Article 2.2.5.16. by including cellular core PVC pipe.

NPC20 Div.B 2.3.4.5.

Impact to Builders

No negative impact on the residential construction industry.

Reduces pipe support spacing in some cases and clearly states requirements for cellular core PVC pipe.

Remain Silent - No Comment

1729 Piping Mechanical Couplings

What: This proposed change adds requirements for plain-end-type mechanical couplings for pressure applications by referencing ANSI/AWWA C227-17, “Bolted, Split-Sleeve Couplings.”

Why: In the absence of such minimum requirements, there is a risk that mechanical couplings of inferior quality could be installed.

NPC20 Div.B 2.2.10.4.

Impact to Builders

Trades installing pressure piping would need to ensure that mechanical couplings comply with the referenced standard.

Remain Silent - No Comment

2024 Water-Use Efficiency Clarification of Maximum Water Usage for Dual-Flush Water Closets

What: This proposed change clarifies the maximum water usage requirements for the full and reduced flush cycles of dual-flush water closets.

Why: This proposed change would eliminate confusion about the maximum water usage per flush cycle permitted for dual-flush water closets by deleting the reference to 4.8 Lpf in Table 2.6.1.6. and replacing it with 6.0/4.1 Lpf. NPC20 Div.B 2.6.1.6.

Impact to Builders

This change should have a positive impact on industry and homeowners, since some plumbers might have been installing water closets with a maximum flush rate of 4.8 Lpf and it will now be clear the maximum is 6.0/4.1 Lpf for dual-flush toilets.

Support As Is

National Fire Code of Canada

2010 Fire Safety Plan Deletion of Redundant Provisions Pointing to the Fire Safety Plan in the NFC

What: This proposed change deletes redundant provisions that refer to Section 2.8., Emergency Planning, from other Parts of the NFC.

Why: References in other parts of the NFC are redundant and can be removed. This is really a clean- up exercise following up on changes made in the 2020 NFC.

NFC20 Div.B 3.1.2.7., NFC20 Div.B 3.2.2.5., NFC20 Div.B 3.2.7.14., NFC20 Div.B 3.3.2., NFC20 Div.B 5.1., NFC20 Div.B 5.2.3., NFC20 Div.B 5.5.3.1., NFC20 Div.B 5.6.1.

Impact to Builders

No impact to industry as this is really just an editorial change.

Remain Silent - No Comment

1807 Large Farm Buildings (General) Flammability of Interior Screens and Curtains in Farm Buildings

NFC20 Div.B 2.3.2.

Impact to Builders

No impact on residential construction industry.

Remain Silent - No Comment 

1844 Withdrawn Document Deletion of Reference to Withdrawn Document

What: This proposed change deletes the reference to ULC/ORD-C410A-94, “Absorbents for Flammable and Combustible Liquids,” from explanatory Note A-4.1.6.3.(3)(b).

Why: At the mid-cycle review of updates to referenced documents in the NFC, it was noted that ULC/ORD-C410A-94 was withdrawn in 2018, and no longer used in practice. Therefore, it was agreed to delete the reference to the withdrawn ORD from the NFC to eliminate potential confusion for Code users.

NFC20 Div.B Other- Hazardous Materials 4.1.6.3.

Impact to Builders

No impact on the residential construction industry.

Remain Silent - No Comment

1805 Storage Tanks Reference to CSA B139:19 Series without Capacity Restriction

What: The proposed change removes the capacity restriction on above ground storage tanks from the reference to CSA B139 Series, "Installation code for oil- burning equipment."

Why: Larger tanks are now addressed under the updated CSA standard and by referring to it, would provide consistent harmonized requirements for aboveground storage tanks.

NFC20 Div.B 4.1.1.1., NFC20 Div.B 4.3.13.1., NFC20 Div.B 4.3.13.4., NFC20 Div.B 4.3.13.5., NFC20 Div.B 4.3.13.6.

Impact to Builders

Would only impact large residential buildings that are heated with oil- burning equipment.

Remain Silent - No Comment