CHBA BC Position on the BC Energy Step Code
This position speaks to the province-at-large. CHBA local associations are the experts on their local conditions and should be the authoritative voice of the industry during municipal consultations.
We do not fear a tiered-code system. It provides predictability and transparency. The biggest danger is inter-governmental pressures that may drive implementation of higher steps before communities are ready. Accelerating market transformation without first resolving market barriers will be problematic for all.
Affordability
Housing affordability should be a core objective in the Building Code, so future levels of improvement do not cost home buyers more. The progression towards the goal of Net Zero Energy Ready by 2032 must remain affordable at all steps, for all housing types, home buyers, and climate zones.
Accessibility
The province must not overlook regional needs and concerns, nor focus solely on areas with the largest housing starts as the measure of success. Accessibility parameters include training, product availability, and access to qualified professionals.
Step by Step
Any implementation challenges must be resolved before widespread regulation or expansion to higher steps can be considered or supported. If a delayed implementation of 2032 targets prevents unintended consequences, it is worth adjusting timelines as needed.
Local governments should be able to follow the Step Code as legislated, beginning at Step One, without undue pressure and benchmarking against other jurisdictions. Voluntary municipal incentives for builders and homeowners can encourage the adoption of higher-than-code steps.
Before implementing the Step Code in new areas, local governments should consider cost-benefit analysis; incentives, including density bonusing, permit timelines, rebates, and more; industry knowledge and capacity; availability of necessary materials; and proximity of licensed energy advisors to ensure a cost-effective and competitive environment.
Acceptance
Energy efficiency is just one of many factors influencing the building process, but not necessarily the most prominent for every home buyer. Imposing future design restrictions on new housing may favour the available options in existing housing—even with a retrofit code in the future. New housing must remain a competitive option.
Another barrier to adoption exists because of design restrictions and guidelines imposed by local governments through bylaws, registered building schemes and restricted covenants that significantly affect energy use. Examples may include heritage or character guidelines, the need for unique form and massing, or building articulation on account of architectural considerations from design panel review.
Harmonization with National Codes
Currently, proposed changes to the National Code are under review that include a Step Code approach to meeting energy performance targets. Given the extensive resources available to the National Code review process, it would be beneficial for B.C. to harmonize with the National Code, especially on items related to the Step Code.
Voluntary Leadership with Home Labelling Programs
CHBA BC is a service organization licensed by Natural Resources Canada. We train energy advisors and deliver some voluntary programs, including EnerGuide, R-2000, ENERGY STAR® for New Homes, and the CHBA Net Zero Home Labelling Program.
We are in full support of all voluntary programs, innovation, and financial incentives to find the best ways of achieving higher levels of performance in a cost-effective way, to give members an advantage, and to provide a great product for customers.
Industry Consultation
Industry and government must be in constant communication. While government is the driver of regulation, builders and industry professionals are the ones actually implementing the changes. Their concerns and ideas must be heard at all times.
This position was approved by the Canadian Home Builders’ Association of British Columbia Board of Directors on June 26, 2019.
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