Passive House Canada Comments on Federal Net Zero Emissions Code – Wave 2

Passive House Canada supports the Canadian Board for Harmonized Construction Codes (CBHCC) and its efforts to include objectives for GHG emissions in the national building codes for new homes and buildings in Canada. This is an important step that must be taken to achieve Canada’s commitment to reduce emissions by 40-45% below 2005 levels by 2030 and to reach net zero emissions by 2050. 

We agree with and support the following Wave 2 additions to the Policy Framework, and have identified several recommendations for consideration below: 

1. That it is appropriate and important to utilize the national model codes to reduce operational and embodied GHG emissions and that it be used in concert with other policy instruments. The proposed timelines are appropriate given the need to build market capacity and understanding of appropriate embodied carbon technical requirements. 

Recommendation: Accelerate the development of the AEB and prioritize the application of GHG objectives for it. Existing buildings make up the majority of emissions and must be addressed as soon as possible. 

2. That a tiered pathway that progresses to zero or near zero be implemented, using a variety of integrated policy tools, including the National Model Codes. 

Recommendation: That a timeline be identified to make tiers mandatory. This approach with create market certainty and drive industry to build capacity. 

3. That GHG emissions requirements be developed in a way that can be integrated in the NBC and NEBC, along with the use of a tiered pathway, allowing PTs flexibility to address different energy source issues. 

Recommendation: If a prescriptive path is to be allowed, that a plan be put in place to phase it out over time and/or that the performance path be heavily incentivized to 

encourage industry to evolve to a performance approach. The prescriptive approach is also known as the reference building approach or percent-better-than approach and is globally recognized as an ineffective way to assess GHG emissions in buildings. If Canada’s stated goal is to reduce building emissions to zero or near zero, the prescriptive approach stands in contrast to this stated goal. 

4. Federal strategies, such as the Greening Government Strategy and the Canada Green Building Strategy are effective and comprehensive policy instruments that will support the transition to low carbon buildings. 

Recommendation: Cross-collaboration between federal divisions is important to ensure an integrated, multifaceted approach that effectively reduces emissions in buildings through policy tools. 

5. That impact analysis be done to consider the affordability of proposed changes.