Passive House Canada Public Review Comments on Federal Net Zero Emissions Code

This past winter, the Canadian Board for Harmonized Construction Codes (CBHCC) sought input from stakeholders, experts, code users, and the general public on their Wave 1 draft policy recommendations for developing and implementing greenhouse gas emissions provisions in the National Model Codes. This input will feed into the development of the final policy framework that will be put in place.

Passive House Canada submitted 10 key recommendations for the CBHCC’s consideration. The inclusion of a policy framework and stated objectives for GHG emissions in the national building codes for new homes and buildings in Canada 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. You can review our submission below.


Passive House Canada Public Review Comments on Federal Net Zero Emissions Code


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. 

Recommendation 1: That the CBHCC develop a zero emissions code rather than a net zero emissions code. Net zero emissions is interpreted differently by various organizations. This level of ambiguity poses a risk that may ultimately harm Canada’s stated climate goals. For example, the use of offsets to achieve net zero emissions for a building means that GHG emissions continue to occur outside the scope of the building code. Further, if industry is focused on how to achieve net zero, or what net zero is, then its focus is not on how to learn and build capacity to get to zero, thereby slowing and delaying a critically important market shift to better quality, healthier, more resilient buildings that reduce their climate impact. 

Recommendation 2: This code should target zero operational emissions for new buildings and homes and set clear emissions reduction targets. 

1. Energy efficiency should be identified as the first step in this process to avoid over reliance on fuel switching and other tactics that are counterproductive to the stated goal of this code and Canada’s climate targets. 

2. Air tightness testing should be used to verify efficiency. Including tracking and monitoring of emissions and energy use will ensure building performance and compliance. 

This is the only way forward that does not have significant negative implications for other sectors. For example, a net zero emissions code that allows for fuel switching to improve energy efficiency but does not result in the construction of buildings that decrease overall energy use will place an undue burden on the electricity grid and may not decrease overall emissions. This raises a host of problems, including increasing electricity use in areas where the grid is not clean (scope 2 emissions). 

Recommendation 3: The development of a net zero emissions code should merge with government energy plans, and those of the IESO and provincial regulators. It should be proportional to how GHGs in buildings will be addressed to mitigate grid capacity concerns. 

Recommendation 4: Avoid net-zero offsets. New buildings of all types can be designed and constructed to be near zero from the outset, by targeting efficiency first, and avoiding locking in emissions for the long-term. Reducing operational and embodied emissions can be done through design and construction, selection of mechanical equipment and lower emissions materials. 

Recommendation 5: Eliminate the building codes’ fuel-agnostic approach that treats all fuels used for building operations equally. Heating sources are not equal when it comes to emissions. To achieve Canada’s climate targets, high efficiency building components must be used. The government should incentivize Canadian production of these products to Passive House, or near Passive House quality and build market capacity, re-localize the supply chain, and increase affordability and accessibility. 

Recommendation 6: This code should specify indoor air quality requirements to ensure the health and safety of occupants. Net zero, near zero and zero emissions buildings are more airtight. Requiring an indoor air quality standard and the use of mechanical heat recovery ventilation systems must be incorporated in the development of this code as a matter of safety. 

Recommendation 7: Use a performance path with an intensity-based metric to set a threshold for the amount of allowable GHG emissions per floor area of the building and include annual heating and cooling energy limits. Ensure this path fits with other existing tiers in the national building codes to avoid ‘gaming’ of the system. 

The code should specify GHGI limits (expressed as kg CO2/m2/year) and incorporate a Thermal Energy Demand Intensity (TEDI) metric to limit the thermal energy losses through the building envelope and Energy Use Intensity (EUI) metric to lower the total amount of direct and indirect energy used for heating, ventilation, and hot water, as well as appliances and equipment. These target metrics should be at or near those identified in the City of Vancouver’s Zero Emissions Building Plan and the City of Toronto’s Toronto Green Standard. 

Avoid the use of the prescriptive path and the reference building approach as it creates opportunities for manipulation and does not produce a reliable estimate of actual building performance. It opens the door for green washing as the building appears energy efficient during design but consumes more energy post-construction. 

Avoid an absolute metric as it does not account for different building types, which will result in increased red tape for industry. It will not result in the building performance outcomes being sought by government. 

Recommendation 8: Incorporate embodied carbon into the net zero emissions code at the outset. The only opportunity to reduce embodied emissions for buildings is at design and construction. Once buildings are built, these emissions are locked in for the lifetime of the building. There are opportunities available right now to reduce embodied carbon based on product selection. 

Recommendation 9: Develop a tiered framework for operational and embodied emissions. This framework should align with and complement the existing energy tiers in the national energy and building codes. The tiers should increase emissions reductions over time to move industry forward to where, collectively, we need to go. For embodied carbon, the code could begin with a ‘measure only’ approach to signal the market that embodied emission reductions are an incoming requirement in the code and that requirements will become increasingly stringent over time. 

Recommendation 10: Consideration should be given to the impact of this code on northern communities. Its development should include consultation with northern communities and government divisions that can ensure that an undue burden is not placed on them when this regulation comes into effect.