Before finalizing the policy framework, the Canadian Board for Harmonized Construction Codes (CBHCC) is looking for input on draft recommendations for greenhouse gas emissions provisions in the National Model Codes.
This objective, which should be incorporated into the 2025 codes according to the CBHCC, would include regulation of both operational and embodied carbon, with embodied carbon being addressed in the 2030 codes.
In the initial stages of developing this policy framework, provinces and territories (PTs) noted eight elements for consideration, including:
- principles and factors that all PTs agree on (e.g. ultimate goal and net zero emission definition, emission factors);
- the need to accommodate the breadth of PT fuel policies, plans and individual PT targets, and coordinate with elements that extend beyond the boundary of the code;
- regional differences (e.g. ability to fuel switch, availability of low embodied carbon materials in Northern and remote areas);
- the boundary of operational emissions (e.g. address scope 1 only? Or address both scope 1 and scope 2 emissions?) and embodied emissions (i.e. determine standard method of analysis);
- impact on affordability (e.g. interplay between energy efficiency and GHG requirements with respect to operational GHG emissions);
- development and availability of data (e.g. better granularity of emission factors for operational carbon, better availability of Environmental Product Declarations for embodied carbon, standard method of analysis for embodied carbon);
- implementation approach (e.g. phased approach, flexible approach to address specific needs of PTs);
- adoption and implementation considerations including market readiness, training, capacity building (monitoring, reviewing and enforcement), and developing tools to enable PTs to harmonize.
Prior to the transition to the new Harmonized Code Development System, the CCBFC agreed to ask the standing committees to start working on developing technical requirements that would address GHG emissions in parallel to the ongoing policy work to address the 8 policy elements, and develop language for a new GHG objective.
To provide input on the policy recommendations, first download them via this link, and then submit comments, and supportive material, to the CBHCC Secretary.This first consultation wave ends on March 30. More information is available online.