National Building Code Part 9 Energy Efficiency: Focus Paper to Assist in the Review of Proposed Changes

National Building Code Part 9 Energy Efficiency: Focus Paper to Assist in the Review of Proposed Changes February 2012 Contents 0. Background and Purpose of the Paper 1. Development of NBC Part 9 Energy Efficiency Requirements 1.1 Schedule 1.2 Commenting on Proposed Changes 2. Affected Code Provisions 3. Introduction to Section 9.36. 2.1 Options for Compliance and Application of the Requirements 2.2 Scope of the Proposed Changes and Structure of the Part 9 EE Requirements 4. General Observations on the Proposed Provisions 4.1 Clarity, Constructability and Availability 4.2 Challenges and es 5. Highlighted Issues and Requirements Energy Performance Target 9.36.1. General (Scope, Application, Compliance, Definitions) 9.36.2. Building Envelope 9.36.3. HVAC Requirements 9.36.4. Service Water Heating System Requirements 9.36.5. Performance Compliance for Housing 6. Costs and Benefits 6.1 Bases for Costing 6.2 Calculation of Cost-Benefit 6.3 Costing for Manufactured Homes Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 1 of 17

0. Background and Purpose of the Paper The provinces and territories are supporting the updating of the National Building Code (NBC) to include energy efficiency requirements in Part 9 Housing and Small Buildings. Depending on the requirements that currently apply where your products are installed, the proposed changes could have a significant impact on housing and small building design and construction. This Focus Paper has been prepared for the use of CMHI members to provide an overview of the proposed changes and to assist in identifying proposed changes on which they may wish to comment. The paper does not discuss all of the proposed provisions. CMHI will be submitting comments. Copies may be obtained by e-mailing achown@cmhi.ca. 1. Development of NBC Part 9 Energy Efficiency Requirements The proposed changes are well along in development. The work has been carried out by a Joint Task Group (JTG) of the Standing Committee on Housing and Small Buildings (SC-HSB) and the Standing Committee on Energy Efficiency in Buildings, and five sub-task groups (stgs). Manufacturers and builders were well represented, and CMHI was instrumental in ensuring that options are provided so that insurmountable obstacles are not created for factoryconstructed buildings. The following describes the remaining steps in the development process. 1.1 Schedule Public Review and Approvals The proposed changes have been published for public review on the national codes website. The public review period runs from 9 January to 2 March 2012. See http://www.nationalcodes.ca/eng/public_review/2012_1/introduction.shtml. After public review, comments will be reviewed by the stg on Code Consolidation and the parent standing committees (April 2012), and recommendations will be forwarded to the Canadian Commission on Building and Fire Codes for final approval (June 2012). Publication and Adoption The new requirements are scheduled to be published later in 2012 as an amendment to the 2010 NBC. Whether and when the requirements are adopted by the various authorities having jurisdiction will vary. Information will be provided to CMHI members as it becomes available. Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 2 of 17

1.2 Commenting on Proposed Changes Proposed Change Forms The proposed change forms (PCFs) are posted individually in Code order and also in a single pdf document. Individual PCFs may address a single sentence through to several articles, with or without related Appendix notes. All comments on the proposed changes must be submitted through the individual PCFs on the national codes website. There is a Comment link at the top and bottom of each PCF. Where specific provisions are referenced in this paper, the code reference is identified along with the web link to the related PCF as shown on the public review web page, and the PCF file name, which can be used to search the pdf document. Guidelines and Instructions Guidelines for providing comments and instructions for submission are provided on the website. It is recommended that commentors review these before preparing comments. 2. Affected Code Provisions The new technical requirements will be provided in Division B, Section 9.36. Energy Efficiency. New provisions are proposed for various other sections of Division B to provide useful crossreferences to the new energy efficiency requirements. New provisions are also proposed for Division A. These recognize energy efficiency as an objective of the NBC and identify related functional statements. A new subsection in Division C will specify reporting requirements where the performance compliance path is followed. 3. Introduction to Section 9.36. 3.1 Options for Compliance and Application of Requirements Options for Compliance Aside from alternative solutions that may always be proposed for compliance with national model codes, Part 9 will provide three approaches to compliance: Prescriptive Path prescriptive requirements including three simple building envelope trade-off options Performance Compliance Path full-building energy-use modeling National Energy Code for Buildings the NECB also provides prescriptive requirements with trade-offs and a performance path. Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 3 of 17

Application of the NBC Part 9 Energy Efficiency Requirements Application of the energy efficiency compliance options depends on building type. Building Type Houses Houses with secondary suites Residential buildings containing only dwelling units and common spaces, where common spaces 20% of floor area Residential buildings not described above Buildings that include only occupancies of C, D, E or F3, or a combination of any of these, where the non-residential portions have a total floor area 300 m² Buildings containing non-residential occupancies, where the non-residential spaces are more than 300m² floor area Buildings containing F2 occupancies of any size Compliance Options Part 9 Part 9 Prescriptive Performance NECB X X X X X X 3.2 Scope of the Proposed Changes and Structure of the Part 9 Requirements Scope of the Proposed Changes The proposed changes to Part 9 will provide requirements and related appendix notes to address: building envelope (thermal transmission and air leakage), heating, ventilating and air-conditioning systems and equipment, service water heating systems and equipment. Note that, if the NECB is followed for compliance, that Code also provides requirements for: lighting, electrical systems and motors. Structure of Section 9.36. The proposed requirements will be provided in five subsections in Section 9.36.: 9.36.1. General (scope, application, compliance options and definitions) 9.36.2. Building Envelope 9.36.3. HVAC Requirements 9.36.4. Service Water Heating System Requirements 9.36.5. Performance Compliance. Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 4 of 17

4. General Observations on Proposed Provisions 4.1 Clarity, Constructability, Availability Recognizing that the Code is a legal document and not written in plain language, clarity of the Code requirements and related Appendix notes is critical to proper interpretation. Code requirements must also recognize the ease or difficulty of various constructions and availability of equipment to meet the requirements. A number of requirements and Appendix notes are identified below under 5. Highlighted Issues and Proposed Changes that manufacturers may wish to review for clarity and constructability. 4.2 Challenges and es Considering the very stringent time constraints imposed on the development of the proposed Part 9 energy efficiency requirements, there is much that the Standing Committees, their Task Group members, and manufacturers and builders involved in the process can be proud of. Although the proposed changes will present some challenges, indicating support for an approach taken or for specific proposed changes is as important as providing critical comments where problems are identified. Where CMHI believes that the Task Group and Standing Committee have done a good job, the requirement is identified in this paper as resulting from a. 4.3 Costs and Cost:Benefit Individual proposed changes may also be reviewed in terms of the cost of the up-grade and cost:benefit. This issue is addressed separately in section 6 of this paper. 5. Highlighted Issues and Requirements Energy Performance Target The JTG was tasked with developing requirements that will achieve, on average, a significantly improved energy performance level compared to current national average home construction. The energy performance that will be achieved by the proposed requirements is considered to reflect a reasonable up-grade over the national average. Depending on current requirements in individual jurisdictions, there may be greater or lesser increases in actual performance. One criticism of the approach taken is that it does not recognize the efficiency of smaller houses compared to larger houses. This is an issue that has been identified for consideration in the next code cycle. Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 5 of 17

9.36.1. General (Scope, Application, Compliance, Definitions) Application Code Reference(s): 9.36.1.2. Compliance A-9.26.2.1.(1)-1 Compliance by Building Type Web Link(s): 9.36.1. Add Scope Application and Defined Terms PCF File Name(s): NBC10-DivB-09.36.01.-add-HSB-EEB-Scope_Application_Generalrevised Consistent with the application of Part 9, the JTG and SC-HSB recognized the administrative overhead that comes with requiring compliance with the NECB rather than Part 9. As far as possible, small buildings other than houses have been kept within the application of Section 9.36. Validation of the approach and consideration of possible further expansion of the application of the Part 9 requirements have been identified for the next code cycle. 9.36.2. Building Envelope Calculation of Building Envelope Areas, Clarity Code Reference(s): 9.36.2.3. Calculation of Areas for Ceilings, Walls, Fenestration and Doors Web Link(s): 9.36.2. Add Subsection 9.36.2. Building Envelope PCF File Name(s): NBC10-DivB-09.36.02.01-04-add-HSB-EEB-Scope_Application_BE Depending on your building designs and whether the building envelope trade-offs or performance path is used, calculation of building envelope areas may or may not be necessary. Calculation of building envelope areas is needed for: determining 2% area allowed for penetrations through the insulation compliance with - the building envelope trade-off options - the performance compliance path. For surface-mounted buildings, gross wall area includes the perimeter area of the rim joists. This is important for the calculation of the fenestration and door to gross wall are ratio (see Building Envelope Trade-offs below) and ensures that gross wall area is measured in the same manner for both surface-mounted buildings and buildings on full foundations. Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 6 of 17

Specification of Thermal Properties Proper interpretation and application of the requirements will be facilitated because the proposed changes use terminology for thermal properties consistent with industry use. That is, thermal resistance (RSI) values are specified for walls, floors and ceilings and overall thermal transmittance (USI) values are specified for windows, doors and skylights, rather than specifying all limits in USI. See also the discussions below on Calculation of Thermal Resistance, Nominal Insulation for Assemblies Above Ground and Nominal Insulation for Walls in Contact with Ground. Calculation of Thermal Resistance Clarity Code Reference(s): 9.36.2.4. Calculation of Effective Thermal Resistance of Assemblies A-9.36.2.4.(1) Compliance Method - Calculation Web Link(s): 9.36.2. Add Subsection 9.36.2. Building Envelope PCF File Name(s): NBC10-DivB-09.36.02.01-04-add-HSB-EEB-Scope_Application_BE Calculation of effective thermal resistance of assemblies is needed for compliance with: the prescriptive requirements where assemblies other than those described in the Appendix are used the building envelope trade-off options the performance compliance path. The proposed Article specifies which components must be included in the calculation of effective thermal resistance and which components may be excluded. The proposed Appendix note describes the relationships between effective and nominal thermal resistance (RSI) and overall thermal transmittance (USI). The note explains how to calculate effective RSI and provides tables of values for use in these calculations. Continuity of Insulation, Clarity Code Reference(s): 9.36.2.5. Continuity of Insulation Web Link: 9.36.2.5. Add Article 9.36.2.5. on Continuity of Insulation PCF File Name(s): NBC10-DivB-09.36.02.05.-add-HSB-EEB-Continuity_Insulation For effective performance, insulation in the building envelope should be continuous. This is not always practical. The proposed changes identify exceptions for some cases and require localized increases in insulation to compensate in others. The proposed changes permit an exception to the insulation continuity requirements where masonry cladding is supported on foundation walls that are insulated on the exterior. Although the detail creates a significant thermal break, the exception is considered to be reasonable until calculations can be done to determine comparative energy savings and cost of maintaining insulation continuity. Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 7 of 17

Insulation for Assemblies Above Ground Constructability Code Reference(s): 9.36.2.6. Required Thermal Characteristics of Opaque Assemblies Above and Not in Contact with Ground Web Link(s): 9.36.2.6. Above-Ground Assemblies: Add thermal resistance values for above-ground assemblies PCF File Name(s): NBC10-DivB-09.36.02.06.-add-HSB-EEB-Above_Ground Tables 9.36.2.6.A and B specify minimum effective thermal resistances (RSI) for above ground assemblies depending on climate zone and whether an HRV is installed. Keeping in mind that the overall level of building energy performance must meet that reflected by the proposed requirements, manufacturers may wish to consider and comment on the construction implications of the specified minimum RSI values, particularly in the colder climate zones. Nominal Insulation for Walls above Ground Clarity Code Reference(s): A-9.36.2.6.(1)-2 Nominal Insulation Values Web Link(s): 9.36.2.6. Above-Ground Assemblies: Add thermal resistance values for above-ground assemblies PCF File Name(s): NBC10-DivB-09.36.02.06.-add-HSB-EEB-Above_Ground The proposed Appendix note identifies some typical above-ground wall constructions that will provide the minimum effective thermal resistances required in the six climate zones. These examples identify nominal thermal resistances of the insulation in these assemblies and the residual thermal resistance provided by other materials. Manufacturers may wish to review the examples to determine whether: the examples include commonly-used wall assemblies the information is clear and easily understood. Attic Insulation, Clarity, Constructability Code Reference(s): 9.36.2.6. Required Thermal Characteristics of Opaque Assemblies Above and Not in Contact with Ground, Sentence (2) Web Link: 9.36.2.6. Above-Ground Assemblies: Add thermal resistance values for above-ground assemblies PCF File Names: NBC10-DivB-09.36.02.06.-add-HSB-EEB-Above_Ground Sentence 9.36.2.6.(2) allows the insulation at the perimeter of attics under sloped roofs to be reduced below the minimums specified in Tables 9.36.2.6.(1) A and B. The Sentence specifies: the absolute minimum nominal level of insulation installed above the exterior walls [RSI 2.52 (R-20)]. This is unusual for some wall assemblies as, for example, attic insulation would not normally be carried to the exterior of a masonry-clad assembly. Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 8 of 17

the maximum distance from the exterior wall before the insulation must comply with the Table values [1200 mm (~4 )]. It is not clear whether this is to be measured from the interior or exterior of the wall. Manufacturers may wish to review this provision to determine whether it describes constructions that are practical and cost-effective in the climate zones in which their products are installed. Note that, for manufactured homes with lower ceiling height, a trade-off option is provided. See Building Envelope Trade-Offs below. Fenestration and Door to Wall Area Ratio Consistent with the concept of a minimum code where issues are regulated only where needed, the proposed requirements do not specify a prescriptive limit on fenestration and door to wall area ratio (FDWR). This recognizes that, on average, FDWR values for housing range between 17% and 22%, and this is considered to be reasonable with respect to energy efficiency. FDWR values are used as reference values in one of the building envelope trade-off options and in the performance path; these also range between 17% and 22%. Window and Door Thermal Performance Code Reference(s): 9.36.2.7. Required Thermal Characteristics of Windows, Doors and Skylights Web Link: 9.36.2.7. Windows, Doors and Skylights: Add thermal characteristics for windows, doors and skylights PCF File Name(s): NBC10-DivB-09.36.02.07.-add-HSB-EEB-Windows_Doors Manufacturers and window producers may wish to compare the maximum specified U- values, or the alternative minimum ER ratings, against available products. An exception is provided for one door to allow for an ornamental entrance. Site-Built Windows and Glazed Doors Code Reference(s): 9.36.2.7. Required Thermal Characteristics of Windows, Doors and Skylights, Sentence (2) Web Link: 9.36.2.7. Windows, Doors and Skylights: Add thermal characteristics for windows, doors and skylights PCF File Name(s): NBC10-DivB-09.36.02.07.-add-HSB-EEB-Windows_Doors Innovative site-builders do not always buy building components off the shelf and it is recognized that atypical fenestration and door systems have and continue to play a positive role in energy efficiency. Consequently, optional prescriptive requirements are proposed for site-built windows and glazed doors. Manufacturers may wish to support inclusion of this provision in recognition of the need for the Code to be flexible. Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 9 of 17

Insulation for Assemblies Below or in Contact with Ground Clarity Code Reference(s): 9.36.2.8. Required Thermal Characteristics of Building Assemblies Below or in Contact With the Ground Web Link: 9.36.2.8. Below-Ground Assemblies: Add thermal resistance values for below-ground assemblies PCF File Name(s): NBC10-DivB-09.36.02.08.-add-HSB-EEB-Below_Ground Tables 9.36.2.8.A and B specify minimum effective thermal resistances (RSI) for assemblies below or in contact with the ground depending on climate zone and whether an HRV is installed. The footnotes and subsequent Sentences provide important information on exceptions and the required extent of insulation for floors-on-ground. Nominal Insulation for Walls in Contact with Ground Clarity Code Reference(s): A-9.36.2.8.(1)-2 Nominal Insulation Values for Below Ground assemblies Web Link: 9.36.2.8. Below-Ground Assemblies: Add thermal resistance values for below-ground assemblies PCF File Name(s): NBC10-DivB-09.36.02.08.-add-HSB-EEB-Below_Ground The proposed Appendix note identifies some typical below-ground wall constructions that will provide the minimum thermal resistances required in the six climate zones. These examples identify nominal thermal resistances of the insulation in these assemblies and the residual thermal resistance provided by other materials. Manufacturers and builders may wish to review the examples to determine whether: the examples include common wall assemblies that builders will use the information is clear and easily understood. Airtightness Testing Code Reference(s): 9.36.2.9. Required Level of Airtightness 9.36.5.11 Building Envelope Proposed House, Sentence (9) Web Link(s): 9.36.2.9. and 9.36.2.10 Airtightness: Add prescriptive airtightness requirements 9.36.5.9. to 9.36.5.12. Proposed House Requirements: Add calculation methods for the proposed house in the Performance Path PCF File Name(s): NBC10-DivB-09.36.02.09-10-add-HSB-EEB-Airtightness NBC10-DivB-09.36.05.9-12.-add-HSB-EEB-Proposed_House Airtightness testing for all Part 9 buildings in all locations in the country is not practical. Consequently, airtightness testing is not required in prescriptive path. Where a manufacturer wishes to trade exceptional airtightness for lower performance of other elements, test values can be input in the performance path. Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 10 of 17

Airtight Construction Clarity, Constructability Code Reference(s): 9.36.2.9. Required Level of Airtightness 9.36.2.10. Construction of Air Barrier Details Web Link: 9.36.2.9. and 9.36.2.10 Airtightness: Add prescriptive airtightness requirements PCF File Name(s): NBC10-DivB-09.36.02.09-10-add-HSB-EEB-Airtightness Article 9.36.2.9. requires building assemblies to comply with either: certain criteria when tested in accordance with ULC S742 Specification for Air Barrier Assemblies, or details described prescriptively in Article 9.36.2.10. The North American Fenestration standard is referenced for minimum airtightness of windows doors and skylights, and properties are specified for materials intended to provide airtightness. Manufacturers may wish to review the prescriptively described details to determine if they reflect current good practice. Building Envelope Trade-Offs Clarity, Code Reference(s): 9.36.2.11. Simple Trade-offs for Above-ground Components of the Building Envelope Web Link(s): 9.36.2.11. Add opaque-to-opaque and transparent-to-transparent trade-off methods [Does not include Sentence (4)] 9.36.2.11. Add Sentence 4 on opaque-to-transparent trade-off method for factory-constructed housing PCF File Name(s): NBC10-DivB-09.36.02.11.-add-HSB-EEB-Simple_Trade-off NBC10-DivB-09.36.02.11.(04)-add-HSB-EEB-Simple_Trade-off_Factory The first PCF describes trades that are allowed where the effective RSI of above-ground opaque elements is decreased provided the effective RSI of other above-ground opaque elements is increased the U-value of windows is increased provided the U-value of other windows is decreased Some limits are placed on the extent to which effective RSI may be reduced. The second PCF [Sentence 9.36.2.11.(4)] describes trades that are allowed where the effective RSI of attic or exposed-floor insulation may be decreased in buildings where there is limited window and door area. These trade-offs are permitted only in singlestorey buildings where ceiling height is lower than standard and the FDWR excluding skylights does not exceed 15%. The trade-off is meant to address height limitations that are imposed by transportation regulations on some factory-constructed buildings while recognizing equivalent performance. The PCFs include related Appendix notes to explain the equations. Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 11 of 17

Manufacturers may wish to review the trade-off options to determine if they provide a useful degree of flexibility in building design and construction without having to resort to the performance compliance path 9.36.3. HVAC Requirements Duct Insulation Code Reference(s): 9.36.3.2. Equipment and Ducts, Sentence(5) A-9.36.3.2.(5)-1 Increased Duct Side Insulation Web Link(s): 9.36.3.2. Equipment and Ducts: Add Sentence 5) on trade-off for duct insulation PCF File Name(s): NBC10-DivB-09.36.03.02.(05)-add-HSB-EEB-Duct_Trade-off Sentence 9.36.3.2.(3) requires ducts installed outside the plane of insulation in the building envelope to be insulated to the same level as required for exterior walls. The exception provided in Sentence (5) allows for a reduction in insulation to as little as RSI 2.11 (R-12) under ducts that are installed below insulated floors provided additional insulation is installed on the sides of the duct. This provides equivalent performance and recognizes challenges faced by some factory-constructed buildings where overall height is limited by transportation regulations. The exception may also address constructability issues where ducting is installed in garages under heated space. Heat Recovery Ventilators (HRVs) Code Reference(s): 9.36.3.9. Heat Recovery Ventilation Web Link: 9.36.3.9. Heat Recovery Ventilation: Add Article on HRV requirements - where installed PCF File Name(s): NBC10-DivB-09.36.03.09.-add-HSB-EEB-HRV_dwelling HRVs are not required on the principal exhaust of a ventilation system. This recognizes the reported frequency of problems with installation, maintenance and operation. Where HRVs are installed, minimum levels of efficiency are specified. As noted above, the contribution of HRVs to energy efficiency is recognized and reduced building envelope insulation levels are permitted where HRVs are installed. [See 9.36.2.6. and 9.26.2.8.] HVAC Equipment Availability, Code Reference(s): 9.36.3.10. Equipment Efficiency Web Link: 9.36.3.10. and 9.36.3.11 Equipment Efficiency: Add Article for minimum required HVAC efficiency ratings PCF File Name(s): NBC10-DivB-09.36.03.10-11.-add-HSB-EEB- Equipment_efficiency_HVAC_Revised Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 12 of 17

The efficiency table for HVAC equipment lists equipment even where no performance limits are specified. This is important so that the equipment can be installed under Part 9 rather than building having to be designed according to the NECB. Manufacturers and builders may wish to review the Table to determine if it includes equipment that is currently being installed or available. 9.36.4. Service Water Heating System Requirements SHW Equipment Availability, Code Reference(s): 9.36.4.2. Equipment Efficiency [Note that article heading on the PCF is incorrectly given as 9.36.1.2.] Web Link: 9.36.4.2. and 9.36.4.3. Equipment Efficiency: Add Article for minimum required SWH efficiency ratings PCF File Name(s): NBC10-DivB-09.36.04.02-03.-add-HSB-EEB- Equipment_efficiency_SWH-revised The efficiency table for SHW equipment lists equipment even where no performance limits are specified. Like HVAC equipment, this is important so that the equipment can be installed without the building having to comply with the NECB. Manufacturers and builders may wish to review the table to determine if it includes equipment that is currently being installed or available. 9.36.5. Performance Compliance for Housing Application Code Reference(s): 9.36.5.1. to 9.36.5.3. Scope, Application, Defined Terms, General Web Link(s): 9.36.5.1. to 9.36.5.3. Add Scope and Application of Performance Path PCF File Name(s): NBC10-DivB-09.36.05.01-03-add-HSB-EEB- Scope_Application_Performance The performance compliance option currently applies only to residential buildings that contain only dwelling units and limited or no common space. Subsection 9.36.5. refers to all of these buildings as houses. Due to time constraints, buildings other than houses must comply with the NECB for performance compliance for the time being. Development of a performance option for non-residential buildings will be considered in the next code cycle. Approach Code Reference(s): 9.36.5.4. to 9.36.5.8. Calculations and Data 9.36.5.9 to 9.36.5.12 Proposed House 9.36.5.13. to 9.36.5.16 Reference House Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 13 of 17

Web Link(s): PCF File Name(s): 9.36.5.4. to 9.36.5.8. Calculation Methods: Add general calculation methods for Performance Path 9.36.5.9. to 9.36.5.12. Proposed House Requirements: Add calculation methods for the proposed house in the Performance Path 9.36.5.13. to 9.36.5.16.Reference House Requirements: Add calculation methods for the reference house in the Performance Path NBC10-DivB-09.36.05.04-08-add-HSB-EEB-Calculation_Performance NBC10-DivB-09.36.05.9-12.-add-HSB-EEB-Proposed_House NBC10-DivB-09.36.05.13-16.-add-HSB-EEB-Reference_House The performance compliance path allows the energy performance of any element of the building to be lower than prescribed provided the reduction is made up by increased performance of another element. Compliance is determined through full-building computer modelling comparing the annual energy consumption of a proposed house with the annual energy consumption of a reference house that complies with the prescriptive requirements. Section 9.36.5. identifies all of the parameters and assumed values that must be used in calculating whole-building annual energy consumption. These include weather data site information operating conditions and schedules for the reference and proposed houses characteristics of the reference and proposed buildings calculation procedures. 6. Costs and Benefits Note: Cost and cost benefit information may be found at: http://www.nationalcodes.ca/eng/public_review/2012_1/cost_benefit_analysis.pdf Links to cost and cost-benefit information are also provided in the PCFs. This information should be used with caution. 6.1 Bases for Costing National Average Construction Because the NBC is a national model code, costing is based on national averages. As a first step, a national average was established for home construction based on a builder survey and data from National Resources Canada (NRCan). This house has the following characteristics: Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 14 of 17

Building Feature Current National Average House Wall insulation RSI eff 2.89 R-20 nominal Attic insulation RSI eff 7.00 R-40 nominal Basement insulation, walls RSI eff 1.82, full height R-12 nominal, full height Basement insulation, floor slabs uninsulated uninsulated Rooms over unheated spaces RSI eff 4.94 R-28 nominal Windows double-glazed, low-e, argon fill, insulated spacers, vinyl frame, USI 1.8 Doors insulated steel door RSI 1.14 insulated steel door R- 6.5 Heating system type and efficiency Gas 90%, forced air Electric 100%, forced air Oil 75% DHW system efficiency Gas 55% Electric 82% Ventilation system mechanical ventilation, no heat recovery ventilator Air conditioning no air-conditioning Heat pumps no heat pumps Because of wide-spread variation in airtightness, the national average varies in this respect. Climate Zone Up-Grade Costs Heating Degree-Days Representative Location 4 3000 Vancouver 3.80 5 3000 to 3999 Toronto 3.20 6 4000 to 4999 Montreal 3.10 7A 5000 to 5999 Winnipeg 2.30 7B 6000 to 6999 Fort McMurray 3.40 8 7000 Yellowknife 4.00 Airtightness, ac/h 50 Costs for complying with the proposed energy efficiency requirements are incremental costs above the cost for the average national house. Incremental costs for up-grading individual building elements have been determined for each of six cities that were selected as being representative of the climate zones in the country. Incremental costs take into account material and labour costs. Note: Incremental costs for individual building elements will be correct for your houses only if 1. the construction of the houses you currently manufacture is the same as in the national average house 2. the material and labour costs at your plant are the same as those for the representative city in the climate zone where your products are installed. Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 15 of 17

6.2 Calculation of Cost-Benefit Averages The cost-benefit information provides consumption, energy savings, percentage energy reduction, cost and benefit for each of the representative cities and a national average. Zone 4 5 6 7A 7B 8 Location Vancouver Toronto Montreal Winnipeg Fort McMurray Yellowknife Energy Saving 4.6% 8.1% 11.1% 12.7% 20.1% 32.9% Cost $1,697 $1,926 $3,943 $4,613 $8,164 $16,299 Benefit (savings per year) $68 $146 $197 $278 $524 $1,317 Like the costing information, the cost-benefit information is based on the national average house and the costs and performance improvements above this national average. The cost-benefit information is also based on particular house configuration and a blended energy cost that combines costs for gas and electricity. Note: The cost-benefit information is correct for your houses only if 1. the houses you currently manufacture are the same as the average national house 2. the material and labour costs in your plant location are the same as those for the representative city in the climate zone where your products are installed 3. the energy type(s) for HVAC and SWH in the houses you currently build are the same as those for the representative city in the climate zone where your products are installed 4. the national blended energy rate is the same as the energy rate where your products are installed Weighting In addition to the national average, the cost-benefit information provides weighted values based on population in each climate zone. National Average National Average Weighted Consumption (kwhe/yr) 38,469 31,420 Savings (kwhe/yr) (%) 6,357 17% 3,480 11% Cost $ 7,102 $ 4,753 Benefit (savings per year) $ 384 $ 210 Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 16 of 17

6.3 Costing for Manufactured Homes CMHI is compiling incremental cost information for an archetype manufactured home. The first set of calculations consider: current provincial and territorial requirements as the baseline to establish the cost of upgrades to the proposed NBC level (Where energy efficiency is not currently regulated, the characteristics of the national average house will be used as the baseline.) material and labour cost data from the representative cities that are more likely to reflect costs at plant locations rather than costs where the products are installed. Preliminary calculations indicate that, for an archetype 16 x 68 home, incremental costs are likely to range between $1,400 and $5,800 with the highest increment for homes in the coldest climate zone. If an authority having jurisdiction applies the energy efficiency requirements to Z240 home, the incremental cost is likely to be higher. Proposed NBC Part 9 Energy Efficiency Requirements February 2012 Page 17 of 17