In early April the Canada Green Building Council (CaGBC) and the Royal Architectural Institute of Canada (RAIC) sent a joint letter to National Research Council (NRC) and other federal government ministers to share industry feedback on the overarching approach and omissions of the National Energy Code for Buildings (NECB) and the National Building Code (NBC).
In addition to the letter, the CaGBC and RAIC also submitted technical feedback for proposed changes to Codes Canada on March 13, 2020.
CaGBC and RAIC suggest that the code requirements should address not only energy efficiency, but also the carbon emissions associated with construction and operations in order to meet the government’s carbon reduction objectives.
In their joint letter, the organizations specific recommendations include:
- Code must address carbon not just energy
- Add operational GHG intensity metrics
- Develop embodied carbon metrics
Among the letters comments:
“Given the lifespan of buildings, it is critical that design for low carbon operations occur today at scale since retrofitting these buildings before 2050 will be costly and difficult to achieve.”
“There are several low-carbon options to heat buildings, and regulations should be adjusted to send a clear signal to building designers that these are preferable and also affordable. Setting a carbon intensity budget gives developers an incentive to connect to potential low-carbon heat sources (e.g. electricity, district energy systems) while still providing the flexibility to use carbon-intensive fuels for high-value uses like cooking, peak heating demand, or back-up heating.”
“GHG emissions associated with the production, use, and end of life of construction materials contribute significantly to the limited global carbon budget and must be addressed as quickly as possible in order to be eliminated by 2050. Studies indicate that optimizing procurement processes can provide a 20-40% reduction of embodied carbon today. To achieve more significant reductions will require the development of new products and materials and the evolution of the entire product value chains – a important reason to begin signaling to the market its importance.”
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