Proposed Energy and Water Efficiency Requirements in Manitoba s Building and Plumbing Codes. Stakeholder Consultation Discussion Paper

Transcription

1 Proposed Energy and Water Efficiency Requirements in Manitoba s Building and Plumbing Codes Stakeholder Consultation Discussion Paper April 2008

2 Manitoba Labour and Immigration Office of the Fire Commissioner Building Policy and Sustainability Unit York Avenue Winnipeg, Manitoba R3C 0P8 Canada Tel: Toll free: Fax: Web: To inquire about the stakeholder consultation, to be added to the list of stakeholders, or to submit comments, please contact: Rodney C. McDonald Manager, Building Policy and Sustainability Web: manitoba.ca/labour/ofc/codeconsultations Tel : Consultation jointly funded by: Natural Resources Canada Manitoba Labour and Immigration, Office of the Fire Commissioner Manitoba Science, Technology, Energy and Mines Manitoba Water Stewardship Manitoba Hydro Please consider using and sharing this document electronically before printing. It is designed for double sided printing. If printing, please consider printing double-sided on a post-consumer recycled content paper.

3 Letter from the Minister Improved energy efficiency practices save money, reduce reliance on imported non-renewable natural gas and help reduce greenhouse gas emissions. For these reasons, Manitoba has become a national leader in promoting energy conservation and efficiency. According to the Consumers Council of Canada, Manitoba is one of five provinces that surpass the National Building Code of Canada requirements to include insulation in new housing construction. Manitoba has been rated first in Canada by the Canadian Energy Efficiency Alliance for the past two years. The province has made it mandatory for new buildings that receive public funds to meet internationally recognized Leadership in Energy and Environmental Design (LEED) green building rating system Silver certification or better. The provincial government is committed to building on these accomplishments and developing a low-carbon economy. The current stakeholder consultation on strengthening the energy efficiency, water efficiency and environmental responsibility of the Manitoba Building Code is based on the work of the Manitoba Energy Code Advisory Committee and the Lake Winnipeg Stewardship Board and builds on provincial strengths in these areas. I am pleased to report that Manitoba has already acted on a number of the recommendations in the Manitoba Energy Code Advisory Committee Report. Manitoba led discussions that resulted in a Natural Resources Canada and the National Research Council announcement of funding for the update of the Model National Energy Code of Canada for Buildings. The province has also appointed a representative of the Manitoba Chapter, Canada Green Building Council, to the Manitoba Building Standards Board. Stakeholder input on the proposed recommendations to improve the energy and water efficiency of Manitoba s construction codes will play an important role in ensuring that the changes to those codes allow: the effective, efficient adoption of building practices that protect Manitobans from higher energy prices Manitobans to benefit from the development of new building and construction technologies and techniques the development of competitive design and construction skills the reduction of provincial greenhouse gas emissions I look forward to receiving the report on the consultation process. Nancy Allan Minister of Labour and Immigration

4 Table of Contents 1. Introduction Background The construction of buildings and homes in Canada is governed by three types of documents: standards, codes and regulations Building and Plumbing Codes and Energy and Water Efficiency The Model National Energy Code for Buildings Energy efficiency The benefits of minimum energy efficiency requirements The Manitoba Energy Code Advisory Committee The Proposed Manitoba Energy Code Non-Code Recommendations Water efficiency The Lake Winnipeg Stewardship Board The Lake Winnipeg Stewardship Board Recommendations Green building...8

5 1. Introduction The provincial government is committed to introducing energy and water efficiency requirements into Manitoba s building and plumbing codes. This discussion paper outlines the energy efficiency and water efficiency measures that have been recommended to the government for inclusion in these codes. In April, May and June 2008, the Building Policy and Sustainability Unit of the Manitoba Office of the Fire Commissioner (OFC) will be consulting with stakeholders on the recommended changes. This consultation is the basis for any proposed regulatory changes to the Manitoba building code and plumbing code on energy and water efficiency. The consultation will focus on energy efficiency recommendations made by the Manitoba Energy Code Advisory Committee and water efficiency recommendations made by the Lake Winnipeg Stewardship Board. The Manitoba Energy Code Advisory Committee called for the adoption of a Manitoba energy code that would govern commercial construction. The Lake Winnipeg Stewardship Board asked the government to require that all new homes have low-flush toilets and low-flow faucets. The consultation will also provide an opportunity to identify any potential barriers within provincial codes and regulations that affect the construction of green buildings. The Building Policy and Sustainability Unit of the OFC is seeking stakeholder response to the following three key questions: 1. What should be the minimum required level of energy efficiency in new and renovated buildings and houses in Manitoba, and how should the requirements be met? 2. Taking into consideration the existing standards and the technologies, how should water efficiency measures be incorporated into the plumbing code? 3. Do the existing Manitoba building, plumbing and fire codes create barriers to the implementation of green building practices or to greener building technologies and products? The rest of this discussion paper is divided into four main sections. The first section provides background on the standards, codes, and regulations governing building construction in Manitoba and Canada. It is followed by separate sections describing the changes that have been recommended to the Manitoba government. It concludes with an invitation for comments on potential barriers in the existing Manitoba building, plumbing, and fire codes to green building practices or to greener building technologies and products. Stakeholders are invited to submit written responses to this discussion paper. The Building Policy and Sustainability Unit of the OFC will also be holding consultation sessions in Winnipeg, Brandon and Thompson where stakeholders can provide comments. Instructions on how to submit your comments can be found at the consultation website at manitoba.ca/labour/ofc/codeconsultations. The deadline to provide comments is June 30, This consultation will result in a report to the Minister of Labour and Immigration, with copies to the Minister of Science, Technology, Energy and Mines and the Minister of Water Stewardship. It will also be given to the Manitoba Building Standards Board, whose members are industry representatives. Following governmental review, any proposed regulatory changes will be drafted and reviewed by the Manitoba Building Standards Board. Stakeholders will then have an opportunity to review the regulatory proposals before legislation is enacted. Stakeholder Consultation Discussion Paper 3

6 2. Background: 2.1. The construction of buildings and homes in Canada is governed by three types of documents: standards, codes and regulations. Standards Standards are prepared by accredited standards writing organizations. In Canada, the Standards Council of Canada accredits such organizations as the Canadian General Standards Board, the Canadian Standards Association and Underwriters Laboratories of Canada. Standards from American organizations, such as the American Society for Testing and Materials (ASTM) and the National Fire Protection Association (NFPA), are also used. Standards describe the important features of a product, service or system. The application of standards helps ensure that products and services are consistent, compatible, effective and safe. It is common for standards to be referenced in a code or regulation. The National Building Code of Canada references over 200 standards. Codes The Canadian Commission on Building and Fire Codes (CCBFC) and its related committees are responsible for the development of model construction codes in Canada. There are currently six such codes; four affect the discussion in this consultation: National Building Code of Canada 2005 National Plumbing Code of Canada 2005 Model National Energy Code of Canada for Buildings 1997 Model National Energy Code of Canada for Houses 1997 The National Building Code (NBC) sets minimum requirements for the design and construction of new buildings. It also applies to the alteration, change of use and demolition of existing buildings. The National Plumbing Code (NPC) sets out technical provisions for the design and installation of new plumbing systems. It also applies to the extension, alteration, renewal and repair of existing plumbing systems. The Model National Energy Code for Buildings (MNECB) is intended to provide guidance for the design of energy efficient buildings. It sets out minimum requirements for features such as the building envelope, heating, ventilation, and air conditioning, lighting and service water heating systems. It takes into account regional construction costs, regional heating fuel types and costs, and regional climate differences. The Model National Energy Code for Houses (MNECH) provides guidance for the planning and construction of energy efficient new houses. The MNECH focuses on residential buildings of three storeys or less and additions of more than 10 square meters. Regulations In Manitoba, construction codes must be adopted by the provincial government as regulations under The Buildings and Mobile Homes Act 1. The National Building Code of Canada 2 has been adopted as the Manitoba Building Code 3 and the National Plumbing Code of Canada 4 has been adopted as the Manitoba Plumbing Code 5. Both regulations include amendments that adapt the application of the national codes to reflect provincial priorities Building and Plumbing Codes and Energy and Water Efficiency The National Building Code is based on four objectives: safety, health, accessibility, and fire and structural protection of buildings. The National Plumbing Code has three objectives: safety, health and protection of buildings and facilities from water and sewage damage. Neither code addresses such issues as energy efficiency, water efficiency, resource conservation or environmental sustainability. Adding these objectives to the national codes would require consensus of all 13 provincial and territorial governments. Currently, the Manitoba Building Code does not contain efficiency or sustainability objectives. Provincial governments do, however, have the authority to incorporate these into their provincial codes. Ontario, for example, has added resource conservation, environmental integrity and conservation of buildings to its building code. The government of British Columbia is proposing the addition of conservation of resources, and environmental health to its code. Another option is for Manitoba to adopt the Model National Energy Code for Buildings as a separate Energy Code under The Buildings and Mobile Homes Act. 4 Stakeholder Consultation Discussion Paper

7 2.3. The Model National Energy Code for Buildings In 1997, the Canadian Commission on Building and Fire Codes published the Model National Energy Code for Buildings, which was intended for use in conjunction with the National Building Code. The Model National Energy Code for Buildings is used by building designers in Canada and is the basis for the Canadian version of the LEED (Leadership in Energy and Environmental Design) Green Building Rating System and Manitoba Hydro s Power Smart Design Standards for commercial buildings. The Model National Energy Code for Buildings is intended to cover all buildings, except: buildings of three storeys or less in building height, having a building area not exceeding 600- square meters and containing only dwelling units, related ancillary service rooms, shared means of egress or garages servicing the units buildings of residential occupancy containing not more than one dwelling unit buildings less than 10-square meters in building area farm buildings (e.g. non-residential buildings located on land devoted to farming, and used for the housing of equipment or livestock, or the production, storage or processing of agricultural produce or feeds) buildings that are exempted by government because the nature or duration of the occupancy makes it impractical to apply the requirements Natural Resources Canada and the National Research Council have partnered to update the Model National Energy Code for Buildings with the understanding that provinces and territories will adopt the updated code when available Energy efficiency 3.1. The benefits of minimum energy efficiency requirements Minimum energy efficiency requirements in building codes have a proven track record. Manitoba has minimum requirements for insulation in new houses in the Manitoba Building Code. This contributed to an overall 19 per cent decrease in natural gas use for residential heating between 1989 and There are, however, no commercial building energy efficiency requirements. As a result, from 1989 to 2003, the commercial building sector s use of natural gas increased by eight per cent. The provincial government has also committed itself to the development of a low-carbon green economy for Manitoba. In making the transition to this low-carbon economy, it has set a goal of reducing greenhouse-gas emissions to six per cent below 1990 levels (no more than 16.9 mega tonnes) by no later than the year Construction strategies that could be used to meet new energy efficiency requirements include: high-performance windows heat recovery systems, particularly for ventilation and cooling systems high-efficient boilers, furnaces, heat pumps, and motors increased insulation in walls and ceilings While these measures may mean higher capital costs, the lower operating costs mean that the increase is usually recovered within three to five years. Increasing building energy efficiency not only results in lower energy use, it can: reduce stress on energy distribution networks lower operating costs serve as an insurance policy to reduce the risk of future exposure to increased energy costs reduce greenhouse gas emissions enhance occupant comfort and health create economic opportunities for product suppliers, designers and builders improve overall building performance From a provincial perspective, increased energy efficiency will allow Manitoba to meet its climatechange objectives and also increase energy exports. It will also improve local business competitiveness and Manitoba s provincial competitiveness. Increased Stakeholder Consultation Discussion Paper 5

8 efficiency in the use of natural gas frees up money for increased investment within Manitoba. Changes in the provincial construction codes will be supported by provincial training to help stakeholders develop the knowledge and skills to work with the new regulations The Manitoba Energy Code Advisory Committee In 2005, the Manitoba government appointed the Manitoba Energy Code Advisory Committee to advise it on energy efficiency requirements for new commercial construction in the province. The committee consisted of 15 people from a cross section of Manitoba s commercial building industry. The committee s 2006 report, Building Energy, Building Leadership, contained 17 main recommendations. 7 The key recommendation was for a Manitoba energy code for all new commercial construction. The overall impact of the adoption of a Manitoba energy code would be the design and construction of buildings with better and more energy efficient components. This could include such things as greater insulation, high-performance windows and efficient lighting. The committee concluded that these measures would improve occupant comfort and have little or no impact on building owners and designers already designing buildings with these better technologies The Proposed Manitoba Energy Code The Manitoba Energy Code Advisory Committee recommendations for a provincial energy code contained the following elements. Basing a Manitoba energy code on the Model National Energy Code for Buildings The committee recommended that a Manitoba energy code be based on the Model National Energy Code for Buildings. Using a national code will promote uniformity in the application and enforcement of building standards across the country. Manitoba professionals will be able to more readily apply their expertise across the country. Manitoba regulators can also make use of implementation and training processes developed for the Model National Energy Code for Buildings by other jurisdictions. Adopting a Manitoba energy code under The Buildings and Mobile Homes Act The Committee recommended that a Manitoba energy code be adopted as a regulation under The Buildings and Mobile Homes Act. Placing all codes and standards for buildings under one act ensures consistency for code users, policy makers, regulators and building officials. Also, it creates the opportunity for a one-stop approval process. Finally, The Buildings and Mobile Homes Act itself invalidates any other construction standards not adopted, established or prescribed under that act. Including amendments to a Model National energy code for Buildings in the Manitoba Energy Code The Model National Energy Code for Buildings has not been updated since 1997 and does not reflect new building technologies, new design and construction practices, current energy prices and construction costs, or concerns about greenhouse-gas emissions. Many conventional construction projects are exceeding the 1997 Model National Energy Code for Buildings. For these reasons, the committee recommended that, when adopting the Model National Energy Code for Buildings, Manitoba include additional energy efficiency requirements. In particular, the committee recommended: prescriptive requirement that the building envelope, heating, ventilation, and air conditioning, lighting and service water heating systems meet a level of building energy efficiency that is 25 per cent better than the Model National Energy Code for Buildings (1997). (The committee also recommended that the 25 per cent per cent target be reduced to 15 per cent better than the Model National Energy Code for Buildings (1997) if studies indicate that the 25 per cent target is not realistic.) allowance for performance based requirements as an alternative to prescriptive requirements to meet a level of building energy efficiency 25 per cent better than the Model National Energy Code for Buildings (1997). the energy code apply to major renovations of existing buildings. (In the case of historic buildings, the committee recommended that the amendments should not conflict with the Standards and Guidelines for the Conservation of Historic Places in Canada.) 6 Stakeholder Consultation Discussion Paper

9 inclusion of acceptance testing in a Manitoba energy code to ensure compliance with the code. (Acceptance testing would assess ventilation systems, space conditioning systems, mechanical systems and lighting controls. Acceptance testing is just one step in building commissioning and should be thought of as the first step to a future long term requirement for fundamental building systems commissioning.) Establish a process for energy code compliance The committee recommended that a code contain a straightforward process for demonstrating and confirming compliance with a Manitoba energy code. The process would operate at both the building and occupancy permit stages. At the building permit stage, there would be different requirements for new large occupancies (Part 3 of the National Building Code) and for smaller non-residential buildings (Part 9 of the National Building Code). In both cases, the authority that administers the Manitoba Building Code would administer a Manitoba energy code. Implementation The committee recommended that a new Manitoba energy code, based on the Model National Energy Code for Buildings (1997) and including the appropriate Manitoba amendments to the Model National Energy Code for Buildings (1997), be adopted as a regulation under The Building and Mobile Homes Act by January The implementation of the regulatory changes would be phased in, to allow the construction industry time to adjust. An Alternative Approach An alternative approach to adopting the Model National Energy Code for Buildings as a Manitoba energy code (with Manitoba specific amendments to the application of the code) would be to incorporate the proposed energy efficiency requirements directly into the Manitoba Building Code. Home Construction While the Manitoba Energy Code Advisory Committee recommendations were for building construction, the province is contemplating the development of energy efficiency requirements to home construction as well. For this reason, it is encouraging stakeholders to comment on the implications of such requirements for both home and building construction. One option would be to adopt the Model National Energy Code for Houses (MNECH). However, no jurisdiction has ever adopted the MNECH and there are no plans, currently, to update the 10-year-old code, while the Model National Energy Code for Buildings is being updated. Finally, Ontario, British Columbia, and Nova Scotia have all indicated they may use the EnerGuide Rating System, as it applies to houses, to regulate a performance based minimum energy efficiency requirement for new houses Non-Code Recommendations Aside from calling for the establishment of an energy code, the committee also recommended: amendments to The Energy Act that would ensure Manitoba Energy, Science and Technology s involvement in the development of a Manitoba energy code. the adoption of a Manitoba energy code within the context of a complete market transformation approach. (The committee took the position that incentives to help shorten the payback period of investments in energy efficiency were necessary to ensure that energy efficiency was profitable for the building industry.) the provision of information resources and supporting education and technical resources, to help build industry capacity. regular review and updating of the Manitoba amendments to a Manitoba energy code evaluation of the code s impact and progress. In its response to the committee report, Manitoba appointed a representative of the Manitoba Chapter, Canada Green Building Council to the Manitoba Building Standards Board in Also, Manitoba chairs the national federal provincial territorial committee that helped convince the Canadian Commission on Building and Fire Codes to update the Model National Energy Code for Buildings. Stakeholder Consultation Discussion Paper 7

10 4. Water efficiency 4.1. The Lake Winnipeg Stewardship Board The Lake Winnipeg Stewardship Board was appointed by the provincial government in 2003 as part of a provincial action plan to protect Lake Winnipeg. The 17-member board released its report, Reducing Nutrient Loading Lake Winnipeg and Its Watershed, in December The report made recommendations in 38 different areas, ranging from watershed management to the regionalization of wastewater treatment. In its discussion of water conservation, the board discussed building construction issues. These affect Lake Winnipeg since a number of water treatment plants are currently operating at capacity. The board concluded that numerous methods and technologies allow for the more efficient use of water in individual homes, business establishments and offices. These technologies include low-flow taps, showers and toilets. The methods include a more efficient use of water, such as the re-use of greywater (wastewater from sinks, showers and laundry) The Lake Winnipeg Stewardship Board Recommendations In its 2006 report, the Lake Winnipeg Stewardship Board made two water efficiency recommendations. Make low-flush toilets and low-flow faucets mandatory The board recommended that all new houses be required to have low-flush toilets and low-flow faucets. 9 Investigate the potential use of greywater The board recommended that Manitoba investigate the handling of greywater in an economic and environmentally sensitive manner. Water efficiency in building construction While the Lake Winnipeg Stewardship Board s recommendations were for house construction, the province is contemplating the development of water efficiency requirements for building construction as well. For this reason, it is encouraging stakeholders to comment on the implications of such requirements for both house and building construction. The board also recommended that all levels of government consider incentives or rebates for homeowners to retrofit fixtures to low-flow alternatives. It suggested that consideration be given to an environmental levee for the purchase of higher volume fixtures. 5. Green building Green building policies can help reduce the costs to operate and maintain buildings and significantly reduce many of the environmental impacts associated with the construction sector. These include the level of greenhouse gas emissions, air and water pollution, solid waste creation and the creation of various waste products. In recognition of the benefit of green building policies, the provincial government has developed a Green Building Policy for Government of Manitoba Funded Projects. This policy applies to new building projects and major renovations of buildings done by any provincial government department, agency and Crown corporation as well as private sector projects receiving government funding. The policy s energy efficiency provision requires a level of building energy efficiency 33 per cent better than the Model National Energy Code for Buildings. The Manitoba government is also committed to expanding the use of green policy practices throughout the province. It also recognizes that aspect of Manitoba s current building construction codes and standards may be hindering the implementation of green building practices. These barriers can arise in a number of ways. In some cases, for example, the existing codes do not deal with certain issues (greywater) while in other cases, they may not reflect recent technological and policy developments. The Manitoba government invites stakeholders to use these consultations as an opportunity to identify such barriers and propose amendments that would enable the industry to adopt green building practices, while also maintaining the health and life safety objectives of the codes. 8 Stakeholder Consultation Discussion Paper

11 1 The Buildings and Mobile Homes Act: 2 National Building Code of Canada: 3 Manitoba Building Code: 4 National Plumbing Code of Canada: 5 Manitoba Plumbing Code: 6 National Research Council. (2007, June). Updating the Model National Energy Code for Buildings. 7 Manitoba Energy Code Advisory Committee. (2006, September). Building energy, building leadership. 8 Natural Resources Canada, Office of Energy Efficiency, EnerGuide Rating System: 9 Lake Winnipeg Stewardship Board. (2006, December). Reducing nutrient loading to Lake Winnipeg and its watershed Green Building Policy for Government of Manitoba Funded Projects. April manitoba.ca

12 Cert no. SW-COC