Proposed Change 2181

Subsections 9.36.2. to 9.36.4., and 9.36.6. of the National Building Code of Canada (NBC) provide the minimum performance, or "base code," requirements upon which the performance improvement levels of the energy performance tiers are based.

Although the Energy Performance Tier 1, in Subsections 9.36.7. to 9.36.10., provides a similar performance level, the base code requirements differ from those of Tier 1.  The slight differences may complicate demonstrating and determining Code compliance for Code users and building officials.

In addition, once a jurisdiction enforces an energy performance tier that is higher than Tier 1, the base code requirements are no longer an independent compliance option, but are instead referenced by the requirements of the higher tier. 

This proposed change removes the reference to the base code requirements in Sentence 9.36.1.3.(1) (and moves some content from Subclauses to Clauses) to avoid confusion about whether the base code requirements are available independently to demonstrate Code compliance.

Removing references to Subsections 9.36.2. to 9.36.4. and 9.36.6. as compliance options in Sentence 9.36.1.3.(1) would reduce confusion for Code users and building officials and ensure that the intended minimum energy performance tiers enforced by a jurisdiction are met.

This proposed change would not impact the minimum performance level for Energy Performance Tier 1. Code users would continue to have four compliance options available for demonstrating compliance with Energy Performance Tier 1.

The Tier 1 prescriptive path requirements in Subsection 9.36.10. reference the base code requirements in Subsections 9.36.2. to 9.36.4. and align with the Tier 1 requirements in the points-based prescriptive trade-off path in Subsection 9.36.9. The incremental cost of installing a heat/energy recovery ventilator, as required by Subsection 9.36.10, could be offset by the reduced cost for lower insulation values.
 
Using the Tier 1 performance requirements in Subsection 9.36.7. rather than those in Subsection 9.36.6. to demonstrate compliance would not result in any additional costs as the requirements are identical.

In addition, the energy use intensity compliance path in Subsection 9.36.8. is available to Code users for demonstrating compliance with Tier 1 and may result in lower incremental construction costs for some types of housing.

This proposed change would benefit Code users and enforcement officials by providing increased clarity.

As the proposed change would simply clarify the available compliance options for minimum energy performance, it would not require additional Code enforcement resources.

Regulators, builders, designers, engineers, architects, contractors and consultants.