Proposed Change 1991

The absence of Code requirements for existing buildings in the NECB has resulted in a patchwork approach to dealing with the alteration of existing buildings across Canada, which causes confusion for the industry, regulators and building owners/operators, and also causes potentially unsafe practices.

Authorities having jurisdiction and the industry have expressed the desire for a set of requirements that can consistently be applied to existing buildings subjected to alteration to ensure an acceptable level of safety and building performance, and that also removes ambiguity as to the degree of work required on the rest of the building. A process for the consistent application of these requirements would help reduce unnecessary variation in enforcement levels in different jurisdictions. The requirements applying to the alteration of existing buildings should be clearly stated in a new Part 13 in the NECB.

The voluntary alteration of an existing building represents an opportunity to upgrade the building’s energy performance. When significant repairs or alterations need to be made is the ideal time to consider upgrading the building’s performance where it is cost-effective to do so, thereby minimizing the incremental cost of the upgrade.

To address the alteration of existing buildings, a guiding principle of the development of provisions is that the provisions should be reasonable, pragmatic and avoid placing an undue burden on building owners. Providing exemptions from or relaxations of Code requirements that are not practical to apply to an existing building, and that do not lead to a decrease in building performance, allows the flexibility to continue using existing functional materials or equipment by extending their service life and deferring replacement costs.

Code users would benefit from a clarification of the requirements that apply to the alteration of existing buildings and the applicable permitted relaxations to Code requirements.

The proposed changes introducing other Subsections of proposed Part 13 applying to the alteration of existing buildings provide the impact analysis for specific technical requirements individually.

It is expected that new proposed Part 13 requirements which apply to the alteration of existing buildings would provide a benefit to both the industry and authorities having jurisdiction by providing a consistent set of provisions to ensure an acceptable level of safety and building performance, and to remove ambiguity with respect to the degree of work required to improve performance in the unaltered portion of the building.

Providing exemptions for maintenance, repair or replacement with a similar component where appropriate would permit extension of the service life of materials and equipment, defer system replacement costs and improve building performance without creating undue burden on building owners.

This proposed change would help reduce administrative and enforcement costs of assessing the degree to which any particular requirement could be relaxed without affecting the level of performance of the building with respect to the Code objectives and as compared to full compliance.

It is expected that a consistent set of provisions that apply to the alteration of existing buildings would help reduce the administrative and enforcement work of assessing the degree to which any particular requirement could be relaxed without affecting the level of performance of the building with respect to the Code objectives.

The proposed changes would aid enforcement by identifying the work necessary to improve energy performance in the unaltered portion of the building.

Designers, specification writers, manufacturers, contractors, building owners and building officials.