CAGBC Feedback on Draft Policy Framework for Climate Change Mitigation

The Canada Green Building Council (CAGBC) strongly supports incorporating operational carbon provisions in the 2025 National Model Codes draft.

CAGBC’s members and stakeholders recognize the critical role buildings will have in meeting Canada’s climate objectives. As such, we support a standardized approach to assess and reduce operational carbon emissions, including establishing carbon reduction objectives for future code updates. A standardized approach will establish a level playing field and send the required strong market signal to drive decarbonization actions by owners, developers, operators, manufacturers, and designers.

Concerning the policy recommendations, we offer the following observations and key considerations:

• Recommendation 1: Adopting energy efficiency tiers in the 2020 editions of the National Energy Code of Canada for Buildings (NECB) and the National Building Code of Canada (NBC) was a positive step. The tiers provide market visibility on the likely pace of future updates and allow leaders to push the industry forward in advance of the codes. CAGBC supports and encourages the introduction of tiers for operational carbon abatement to assist with the market transition.
• Recommendation 2: CAGBC recognizes regional differences in ambition for operational carbon reduction and energy efficiency. While all regions of Canada must electrify now to reduce operational carbon emissions, CAGBC supports flexibility for provincial and territorial jurisdictions to adopt operational carbon and energy efficiency tiers independently.
• Recommendation 3: CAGBC supports the inclusion of scope 1 and scope 2 emissions. Regarding concerns that only including scope 1 emissions “could lead to design choices that do not reduce GHG emissions overall,” it is important that emissions are evaluated over the life of the space heating equipment, typically 15 to 30 years. While the operational carbon from an electrified space heating system may initially be higher in a few jurisdictions due to the carbon intensity of the electrical grid, the total emissions over the lifespan of the heating equipment can be expected to be lower as electrical grids are decarbonized.
• Recommendation 4: CAGBC supports the adoption of Environment and Climate Change Canada’s future emission factors for grid electricity. These factors more accurately reflect the context in which mechanical space heating systems will operate over their lifespans. The future emissions factors should represent the average of the next 15 years, which represents the lower end of the typical lifespan of space heating systems in large buildings and aligns with the expected lifespan of heating systems used in homes.
• Recommendation 5: CAGBC supports the development of both performance and prescriptive options for the NBC and NECB, recognizing that energy modelling is not typical or required for all building types and asset classes.
• Recommendation 6: The choice of metrics to assess operational GHG emissions is complex, with substantial advantages and disadvantages to each approach. Recognizing that some building types do not lend themselves to intensity-based or absolute metrics due to the variation in space uses (e.g., community centers that might include ice pads, swimming pools, gymnasia, and other unique space uses), a reference building metric is necessary.