This proposed change introduces an energy performance compliance path based on the energy use intensity target of the building.
Related Proposed Change(s):
PCF 1869
Problem
The current energy performance path in the National Energy Code of Canada for Buildings (NECB) uses a “proposed versus reference” approach to demonstrate compliance with the Code. In this approach, an energy model for the entire building that represents the proposed building design is created following the requirements of Part8 of DivisionB of the NECB. An energy model for the reference building is then created in a similar fashion, but using the appropriate prescriptive requirements in Parts3 to 7 of the NECB instead of the proposed design parameters. A building is deemed compliant with Part8 if the modeled proposed building uses no more energy than the reference building. This approach is commonly used by many energy codes.
As the NECB becomes more stringent and aspires to a net-zero energy level of performance, the "proposed versus reference" approach in the performance path becomes less efficient in its ability to reduce energy use in buildings. The following are some of the flaws of this compliance approach.
1. The prescriptive requirements of the NECB are used to set the minimum performance level of the proposed building and the NECB is also used in the modeling of the reference building. As the required performance level of the proposed building increases, specific prescriptive energy conservation measures could be favoured while invalidating others, limiting the design options to which building designers have access and pushing the market toward more uniform design solutions and a limited set of technologies that may prove to be unsuitable for some categories of building archetypes or in the future.
2. The NECB performance path was not designed to accommodate increasing levels of “percent better than” comparison; rather, it was designed as a binary pass/fail test. This is evidenced by the following.
a. Different design paths leading to different applicable prescriptive requirements. In the current prescriptive requirements and reference building modeling rulesets, the energy consumption of the reference building can change significantly as a result of proposed design choices, even if those choices have only marginal impact on the energy consumption of the proposed design. For example, switching heating systems from heat pump to boiler results in a similar change in the reference building and thus increases the reference energy consumption.
b. Aligning modeling procedures across jurisdictions. Many authorities having jurisdiction express their requirements as “percent better than” Code values. However, due to the limitations noted here, authorities having jurisdiction have implemented various modifications to the current performance path rules to allow projects to demonstrate higher savings. These modifications create a patchwork of energy modeling procedures that vary across Canada. This issue is avoided with an energy use intensity approach, where it presents an opportunity to streamline or eliminate local modeling variations, that is independent of the energy performance tier or “percent better than” targets set by each jurisdiction.
3. The NECB performance path may be limited in its ability to meet its intended objective, i.e., reducing excessive use of energy. Due to the effect of different design paths leading to different prescriptive requirements (2(a) above), potential energy savings under the current performance path may be constrained by the ruleset that determines the energy consumption of the reference building and have less effect on energy reduction in the proposed building.
4. Additional effort is required and potential to introduce errors exists when creating a reference building model. Creating an energy model to represent the energy performance of a proposed design (based on drawings and specifications) depends on the interpretation of the energy modeler. The rulesets for creating the reference building, while sometimes clear and precise, can at other times be ambiguous and open to interpretation as well.
Failure to provide Code users with an alternative energy performance path to the "proposed versus reference" approach to demonstrate compliance with the performance path of the NECB would limit the options available for Code users to improve building energy performance to meet the objective of minimizing excessive use of energy.
Justification
Introducing absolute energy targets in the NECB would allow designers to directly measure the intended impact of design choices, specifically in terms of energy consumption. Design decisions that impact these metrics would be reflected in the energy performance of the energy model.
The proposed absolute energy targets take into account climate zones and building size and typology. As not all building typologies can be represented, the most significant archetypes in terms of annual construction in Canada would be targeted.
This proposed change would enable the NECB to facilitate the design of net-zero energy ready buildings by setting absolute energy targets that represent the minimum energy consumption that can reasonably be achieved for the given building typology and climate zone. This proposed change would also streamline performance path compliance by reducing energy modeling effort and removing the need to interpret the reference building ruleset.
The proposed compliance path based on absolute energy targets would make it more cost-effective for Code users to comply with Code requirements when using designs that minimize the building envelope to floor area ratios or optimize ventilation air. The proposed change would permit Code users to use lower insulation levels in more compact building designs, due to the fact that these buildings naturally consume less energy due to their smaller building envelope area. Finally, this proposed compliance path would enable flexibility in the choice of heating, ventilation and air-conditioning systems by allowing any type of system to be selected.
PROPOSED CHANGE
[1.1.2.1.] 1.1.2.1.Prescriptive, Trade-off or Performance Compliance
Note A-1.1.2.1.NECB Compliance Options.
Figure A-1.1.2.1. shows the three compliance options available in Division B.
Figure [A-1.1.2.1.] A-1.1.2.1. Decision flow chart for Code compliance
[8.4.] 8.4. Performance Path
[8.4.1.] 8.4.1. Compliance
[8.4.1.1.] 8.4.1.1.General
[8.4.1.2.] 8.4.1.2.Determination of Compliance
[1] 1)Subject to the limitations stated in Article 8.4.1.3., compliance with this Part shall be determined based on Sentences (2)to (5).
[2] 2)The annual energy consumption of the proposed building, in kWh per year, as determined in accordance with this Part, shall not exceed the building energy target of the reference building, in kWh per year, as determined in accordance with.
[a] a)Subsection 8.4.4.-2025, or
[b] a)Subsection 8.4.5.-2025.
[3] 3)The number of hours during which the heating loads for each thermal block are not met shall not exceed 100 hours in a simulated year for both the proposed building and, where applicable, for the reference buildings.
[4] 4)The number of hours during which the cooling loads for each thermal block of the proposed buildingfor which mechanical cooling is provided are not met shall
[a] a)not exceed 100 hours in a simulated year for the proposed building when complying with Subsection 8.4.4.-2025, or
[b] a)not differ by more than ±10%or 20 hours, whichever is greater, from the number of hours in a simulated year thatduring which the cooling loads for each thermal block of the reference building are not met when complying with Subsection 8.4.5.-2025.
[5] 5)Where the requirements of Sentences (3)and (4) are not met, the capacities of the primary and secondary systems of the proposed building or the reference building, where applicable, shall be incrementally increased until those loads are met.
[8.4.1.3.] 8.4.1.3.Limitations
[8.4.1.4.] 8.4.1.4.Treatment of Additions
[8.4.1.5.] ---Treatment of Process Loads
[1] --)Except as provided in Sentence (2), the energy consumed by process loads need not be included in the energy model of the proposed building.
[2] --)Where the effects of process loads are included to reduce the annual energy consumption of the proposed building, the energy consumed by the process loads shall be accounted for in the modeling of the proposed building and in the calculation of the building energy target. (See also Note A-8.4.2.7.(1).)
[8.4.2.] 8.4.2. Compliance Calculations
[8.4.2.1.] 8.4.2.1.General
[8.4.2.2.] 8.4.2.2.Calculation Methods
[1] 1)Except as provided in Sentence (5), the energy model calculations shall account for the annual energy consumptionannual energy use of
[a] a)space-heating equipment,
[b] b)space-cooling equipment,
[c] c)fans,
[d] d)interior and exterior lighting devices,
[e] e)service water heating equipment,
[f] f)pumps,
[g] g)auxiliary HVAC equipment (see Note A-8.4.2.2.(1)(g)PROPOSED CHANGE A-8.4.2.2.(1)(g)),
[h] h)receptacle loads and miscellaneous equipment as per Article 8.4.2.7.,
[i] i)appliances, and
[j] j)elevators and escalators.
[2] 2)The energy model calculations shall be performed for a one-year period (8 760 hours) using time intervals no greater than one hour.
[3] 3)Operating schedules and climatic data input in the energy model shall use a time interval no greater than one hour.
[4] 4)If a computer program is used to carry out the compliance calculations, the calculation methods employed in the energy model shall conform to
[a] a)ANSI/ASHRAE 140, "Standard Method of Test for the Evaluation of Building Energy Analysis Computer Programs", or
[b] b)an equivalent test method.
[5] 5)Redundant or back-up equipment is permitted to be excluded from the energy model, provided it is equipped with controls that operate the equipment only when the primary equipment is not operating.
[8.4.2.3.] 8.4.2.3.Climatic Data
[8.4.2.4.] 8.4.2.4.Thermal Mass
[8.4.2.5.] 8.4.2.5.Space Temperature
[8.4.2.6.] 8.4.2.6.Heat Transfer Between Thermal Blocks
[8.4.2.7.] 8.4.2.7.Internal and Service Water Heating Loads
[8.4.2.8.] 8.4.2.8.Building Envelope
[8.4.2.9.] 8.4.2.9.Air Leakage
[8.4.2.10.] 8.4.2.10.HVAC Systems Calculations
[1] 1)For the purpose of compliance calculations in accordance with the requirements of Subsection 8.4.5.-2025, the reference building's HVAC systems determined in accordance with Article 8.4.5.7.-2025Article 8.4.4.7. shall be modeled without substituting their components with thermodynamically similar components or using approximated calculations.
[2] 2)The energy model calculations shall account for the effect of terminal devices, primary systems and secondary systems having limited capacities on space temperature and energy use.
[3] 3)Where applicable, the energy modeling of secondary systems shall account for
[a] a)temperature rise of supply air due to heat from supply fan,
[b] b)temperature rise of return air due to heat from return fan,
[c] c)temperature rise of return air due to heat gain from lights,
[d] d)fan power as a function of supply airflow,
[e] e)temperature and humidity rise or drop of supply or return air due to heat (sensible and latent energy) transferred from a heat-recovery device, and
[f] f)temperature rise of the outside air due to preheaters.
[4] 4)The energy model calculations shall determine how many hours the primary system, secondary system and terminal device loads are not met.
[5] 5)The energy model calculations shall account for the efficiency and capacity of the HVAC equipment as a function of part load and parameters such as, but not limited to, the temperatures of entering fluids and climatic conditions.
[8.4.3.] 8.4.3. Annual Energy Consumption of Proposed Building
[8.4.3.1.] 8.4.3.1.General
[1] 1)The annual energy consumption of the proposed building shall be calculated as described in this Subsection.
[2] 2)Except as stated otherwise in this Subsection, the energy model shall be consistent with the proposed building's specifications including proper accounting of
[a] a)fenestration, doors and opaque building assembly types and areas,
[b] b)lighting systems and controls,
[c] c)HVAC system types, capacities and controls,
[d] d)service water heating system types, capacities and controls, and
[e] e)electrical systems.
[3] 3)The energy model calculations shall include
[a] --)all the energy use addressed in Sections 3.2., 4.2., 5.2., 6.2.and 7.2., and
[b] --)all spaces within the building.
[4] 4)Each conditioned thermal block in the proposed building shall be modeled as being
[a] a)heated, if only heating systems are provided,
[b] b)cooled, if only cooling systems are provided, and
[c] c)heated and cooled, if complete heating and cooling systems or only rough-ins are provided.
[5] 5)For the purpose of compliance calculations, where a building system or part of a building system has not been fully specified, it shall be assumed that it complies with the prescriptive requirements.
[6] 6)Where a building envelope assembly covers less than 5% of the total area of that assembly type, it is permitted to be excluded from the energy model, provided its area is included in an adjacent assembly having a similar U-value and the same orientation.
[7] 7)The energy model calculations shall not include manually operated fenestration shading devices, such as blinds or shades.
[8] 8)The energy model calculations shall include permanent fenestration shading devices, such as fins, overhangs, and light shelves.
[8.4.3.2.] 8.4.3.2.Operating Schedules, Internal Loads, Service Water Heating Loads and Set-point Temperature
[1] 1)The operating schedules relating to the presence of occupants and of loads due to the operation of lighting, receptacle equipment, and heating, cooling and service water heating systems shall be representative of the proposed building's type or space functions. (See Note A-8.4.3.2.(1)PROPOSED CHANGE A-8.4.3.2.(1).)set in accordance with
[a] --)Article 8.4.4.2.-2025, when complying with Subsection 8.4.4.-2025, or
[b] --)Sentences (2) and (3), when complying with Subsection 8.4.5.-2025. (See Note A-8.4.3.2.(1)(b).)
[2] 2)Internal loads, service water heating loads, and illuminance levels used in the energy compliance calculations shall be representative of the proposed building's type or space functions. (See Note A-8.4.3.2.(2)PROPOSED CHANGE A-8.4.3.2.(2).)
[3] 3)For semi-heated buildings, as defined in Sentence 1.2.1.2.(2), the set-point temperature of the proposed building shall be that shown in the specifications.
[8.4.3.3.] 8.4.3.3.Building Envelope Components
[8.4.3.4.] 8.4.3.4.Interior Lighting
[8.4.3.5.] 8.4.3.5.Purchased Energy
[8.4.3.6.] 8.4.3.6.Outdoor Air
[1] 1)For the purpose of compliance calculations, the peak outdoor air ventilation rates shall be set
[a] --)in accordance with Article 8.4.4.2., when complying with Subsection 8.4.4.-2025, or
[b] --)to the minimum rates required by the applicable ventilation standard, based on the proposed building's specifications, when complying with Subsection 8.4.5.-2025. (See Note A-8.4.3.6.(1)PROPOSED CHANGE A-8.4.3.6.(1).) (See also Note A-5.2.3.4.(1)PROPOSED CHANGE A-5.2.3.4.(1).)
[8.4.3.7.] 8.4.3.7.Space Temperature Control
[8.4.3.8.] 8.4.3.8.Part-Load Performance Curves
[8.4.3.9.] 8.4.3.9.Ice Plants
[8.4.4.] -- Energy Use Intensity
[8.4.4.1.] ---General
[1] --)This Subsection shall only be used to demonstrate compliance where 90% or more of the sum of the gross interior floor areas for each known space use of the proposed building, as calculated in accordance with Sentence (3), is associated with one of the building archetypes listed in Table 8.4.4.1.-2025. (See Note A-8.4.4.1.(1)-2025.)
Table [8.4.4.1.] Energy Use Intensities for Building Archetypes
Forming Part of Sentence 8.4.4.1.(1)
Multi-unit residential building, not more than 6 storeys
225
Multi-unit residential building, more than 6 storeys
175
Office
175
[2] --)For the purpose of compliance with this Subsection, the building energy target (BET), in kWh per year, of the reference building shall be calculated as follows:
where
i
= identifier of a building archetype listed in Table 8.4.4.1.-2025 that is associated with a space use of the building,
n
= total number of building archetypes listed in Table 8.4.4.1.-2025 that are associated with the building,
Ai
= gross interior floor area of the building archetype i, in m², calculated in accordance with Sentence 8.4.4.1.(3)-2025,
EUIi
= energy use intensity, in kWh/m² per year, listed in Table 8.4.4.1.-2025 for building archetype i, and
PL
= annual energy use of the process loads accounted for in the calculation of the annual energy consumption of the proposed building, in excess of the default peak receptacle loads set in Table 8.4.4.2.-2025, in kWh per year.
[3] --)The gross interior floor area of a building archetype shall be the sum of the interior floor areas of all conditioned spaces that are associated with this building archetype, as modeled in the proposed building, measured from the inside of exterior walls or the middle line of partitions separating a space use represented by this building archetype from a space use represented by another building archetype. (See Note A-8.4.4.1.(3)-2025.)
[4] --)Space functions not associated with a building archetype listed in Table 8.4.4.1.-2025 shall be distributed proportionally among the listed building archetypes so that the sum of the gross interior floor areas used in Sentence (2)-2025 is equal to the total floor area defined in the proposed building energy model.
[5] --)Where the exterior lighting devices of the proposed building do not comply with the prescriptive requirements of Part 4, their annual energy use shall be accounted for in the calculations as part of
[a] --)the annual energy consumption of the proposed building, and
[b] --)the process loads used in Sentence (2)-2025, where the exterior lighting devices are
[i] --)set to comply with the prescriptive requirements of Section 4.2, and
[ii] --)modeled using the operating schedules referred to in Article 8.4.4.2.-2025.
[8.4.4.2.] ---Operating Schedules and Internal and Service Water Heating Loads
[1] --)For the purpose of compliance with this Subsection, the proposed building's operating schedules and internal and service water heating loads shall be set to the schedules and values indicated in Table 8.4.4.2.-2025 for the applicable building archetype. (See Note A-8.4.4.2.(1)-2025.)
Table [8.4.4.2.] Modeling Inputs for the Proposed Building
Forming Part of Sentence 8.4.4.2.(1)
[2] --)For the purpose of compliance with this Subsection, the peak outdoor air ventilation rates defined in the proposed building model shall be set to the rates indicated in the proposed building's specifications.
[8.4.5.] 8.4.4. Building Energy Target of theModeled Reference Building
[8.4.5.1.] 8.4.4.1.General
[1] 1)For the purpose of compliance with this Subsection,Tthe building energy target of the reference building, in kWh per year, shall be calculated based on the parameters describedrequirements in this Subsection.
[2] 2)The building components and systems of the reference building shall meet the prescriptive requirements of Sections 3.2., 4.2., 5.2., 6.2.and 7.2.for the climate zone under consideration.
[3] 3)The energy model calculations shall include all the energy uses addressed in Sections 3.2., 4.2., 5.2., 6.2.and 7.2.
[4] 4)Except as noted otherwise in this Subsection, the following characteristics of the reference building shall be modeled as being identical to those of the proposed building:
[a] a)total floor area of conditioned and unconditioned spaces,
[b] b)use of building spaces,
[c] c)number, type and conditioning of thermal blocks,
[d] d)shape and exterior dimensions, and
[e] e)orientation.
[5] 5)The presence or absence of heating and/or cooling systems in each conditioned thermal block of the reference building shall be modeled as being identical to those in the proposed building.
[6] 6)Climatic data used in the compliance calculations for the proposed building shall be applied.
[7] 7)The simulation shall account for the effect of part-load operation on equipment performance.
[8.4.5.2.] 8.4.4.2.Operating Schedules, Internal Loads, Service Water Heating Loads and Set-point Temperature
[8.4.5.3.] 8.4.4.3.Building Envelope Components
[8.4.5.4.] 8.4.4.4.Thermal Mass
[8.4.5.5.] 8.4.4.5.Lighting
[8.4.5.6.] 8.4.4.6.Purchased Energy
[8.4.5.7.] 8.4.4.7.HVAC System Selection
[8.4.5.8.] 8.4.4.8.Equipment Oversizing
[8.4.5.9.] 8.4.4.9.Heating System
[8.4.5.10.] 8.4.4.10.Cooling Systems
[8.4.5.11.] 8.4.4.11.Cooling Tower Systems
[8.4.5.12.] 8.4.4.12.Cooling with Outside Air
[8.4.5.13.] 8.4.4.13.Heat Pumps
[8.4.5.14.] 8.4.4.14.Hydronic Pumps
[8.4.5.15.] 8.4.4.15.Outdoor Air
[8.4.5.16.] 8.4.4.16.Space Temperature Control
[8.4.5.17.] 8.4.4.17.Fans
[8.4.5.18.] 8.4.4.18.Supply Air Systems
[8.4.5.19.] 8.4.4.19.Energy Recovery Systems
[8.4.5.20.] 8.4.4.20.Service Water Heating Systems
[8.4.6.9.] 8.4.5.9.Fuel-Fired Service Water Heater
Note A-8.4.3.6.(1)(b)Outdoor Air.
The basic ventilation rates for the proposed building must be set to the minimum rates required by the applicable standards. If the HVAC system includes demand control ventilation strategies, the basic rates can then be adjusted in the energy model calculations to reflect their operation.
While the Code does not restrict modeling of any demand control ventilation strategies implemented in the proposed building, their effectiveness varies significantly from one application to another. As such, only demand control ventilation strategies that are known to reliably generate energy savings should be modeled, and this, in such a way as to avoid overestimating those savings.
Note A-8.4.4.1.(1)-2025Space Uses Associated with a Building Archetype.
A building archetype includes all space uses directly represented by that archetype. The building archetype also includes the common and ancillary spaces normally associated with that archetype and needed for its operation. For example, the office building archetype typically includes offices, conference rooms, employee lounges or break rooms, corridors, lobbies, stairways, washrooms and service rooms.
However, a heated parking garage located on the office building site and included within the building envelope would be associated with a different building archetype since the office building is able to serve its purpose without the parking garage. In this example, the parking garage and its common and ancillary spaces would not be permitted to be included in the energy model of the proposed building or in the calculation of the building energy target.
Note A-Table 8.4.4.1.-2025Energy Use Intensity in the Coldest Climates.
Statistical analysis of the results of modeling multiple permutations of each building archetype in different locations across Canada indicates that the average and range of energy use intensities (EUIs) for each building archetype remain relatively similar across climate zones.
This is largely due to the fact that the applicable prescriptive requirements in Sections 3.2, 4.2 and 7.2 become increasingly stringent as the heating-degree-days (HDD) of the climate zone increase (generally, in steps of 1000 HDD). However, climate zone 8 (HDD ≥ 7000) encompasses a large range of locations, some with HDD ≥ 11 000, which are covered by a single set of prescriptive requirements. It has been observed that the EUIs for building archetypes in locations with HDD ≥ 9000 diverge from those for building archetypes in other locations. Consequently, for these locations, compliance using Subsection 8.4.4.-2025 is not recommended.
Note A-8.4.4.1.(3)-2025Calculation of the Gross Interior Floor Area.
The gross interior floor area generally includes all floor areas enclosed by the building envelope. It excludes exterior lighted areas and heated or unheated parking garages. It also excludes floor areas with space uses not associated with the building archetypes listed in Table 8.4.4.1.-2025 (e.g., retail facilities). As used in the NECB, this term is not intended to mean gross floor area as defined by some authorities having jurisdiction or their bylaws.
Note A-8.4.4.2.(1)-2025Operating Schedules and Load Values for Modeling the Proposed Building.
Because the energy consumption of a building is greatly influenced by internal loads and their demand profiles and by equipment operating schedules, it is important that the model of the proposed building use the schedules and values indicated in Table 8.4.4.2. Since these schedules and values were used to establish the energy use intensity for each building archetype, they must be used in the model even if they are deemed non-representative of the actual expected operation of the proposed building. Using different schedules and values could result in an unsuitable comparison between the annual energy consumption and the building energy target, which could potentially be unjustly advantageous or penalizing to the proposed building. The energy modeler may distribute these schedules and load values across the thermal zones of the energy model, as appropriate for the space functions modeled, as long as the building's average matches the schedules and values indicated for the associated archetype.
Impact analysis
This proposed change provides an additional compliance path for meeting the energy conservation requirements of Part 8 of the NECB. This proposed change does not limit or restrict the continued use of the existing compliance path provided in Part 8. Code users who deem the energy use intensity (EUI) compliance path to be less attractive than the existing prescriptive or performance paths available in the NECB may continue to comply via those other paths. Accordingly, this proposed change is not expected to increase the cost or effort required to comply with the NECB.
However, many builders will likely find that complying via the EUI compliance path is simpler and less expensive than compliance via the existing prescriptive or performance paths. This outcome is expected because the EUI path recognizes the energy savings inherent in more compact building designs. Where the NECB’s “proposed versus reference” approach limits compliance measures to improved building envelopes and enhanced efficiency, the proposed EUI compliance path would offer Code users another tool (i.e., reducing building envelope area and HVAC system type selection) to achieve the same objective.
Research conducted by the National Research Council Canada (NRC) supports this conclusion. NRC analyzed the various compliance paths using various building archetypes (i.e., office, school and multi-unit residential buildings) in different locations across Canada. Each of these building architypes was evaluated by floorplate (e.g., rectangular, T-shape and L-shape), number of storeys and width-to-depth aspect ratio. All models were configured to reflect the reference building design of Part 8.
When the compliance of these same building archetypes was assessed via the proposed EUI compliance path, NRC found that approximately 70% of the building archetypes achieved at least Energy Performance Tier 1 without further modification.
In practice, this result means that builders of compact buildings would face lower costs to achieve Code compliance. Builders of highly compact and attached buildings could achieve higher energy performance tiers with zero cost increase. And all builders would have a new tool (architectural form) available to reduce the cost of achieving higher energy performance tiers. As a result of this proposed change, the massing and, therefore, architectural compactness of some commercial buildings under the NECB may be restricted in practice by the proposed site plan requirements. However, these projects would have the choice of using the existing "proposed versus reference" compliance path.
Enforcement implications
Projects currently using the performance path that elect to use this proposed compliance path based on absolute energy targets would not require any additional enforcement resources.
The proposed design energy model is largely the same as the existing model being submitted, and the reference model would not need to be submitted.
As a result, this proposed change reduces the effort involved in reviewing submissions. The authority having jurisdiction need only review the proposed design model submission against the performance target.
Who is affected
This proposed change would affect designers, engineers, architects, builders and energy consultants who choose to use the proposed compliance path when demonstrating Code compliance. Building officials would also be affected.
Code users who opt to use the proposed compliance path may find that the administration of performance compliance is somewhat easier, as they would only be required to submit one building model instead of two.
Builders would be able to use changes in architectural form as a means to meet energy conservation requirements as well as choose HVAC systems with lower energy consumption.
OBJECTIVE-BASED ANALYSIS OF NEW OR CHANGED PROVISIONS
