An signed copy of these comments will be emailed to firstname.lastname@example.org.
September 29, 2017
2017 Next Edition Building Code Consultation
c/o Building and Development Branch
Ministry of Municipal Affairs
16th Floor - 777 Bay Street
Toronto, Ontario, M5G 2E5
Re: Potential Changes to Ontario’s Building Code
In December 2016, York Region provided comments to the Ministry of Municipal Affairs (MMA) during the initial round of consultations on the OBC. In our response, York Region commented on the need to prevent inflow and infiltration into municipal and regional sanitary sewers and the importance of radon mitigation.
York Region staff appreciates the additional opportunity to provide comments that can be integrated into the next Ontario Building Code update. York Region is supportive of the proposed changes to Ontario’s Building Code to increase the energy efficiency of buildings and support the implementation of Ontario’s Climate Change Action Plan. York Region’s comments are provided in the attached table and summarized below:
Energy Efficiency requirements for new and retrofitted buildings supports long term and community energy planning efforts
As an active participant in long term and community energy planning exercises, York Region is aware of the importance of retrofitting our existing communities to be more energy efficient. Expanding the energy efficiency targets to address renovations in houses and large buildings supports the implementation of the objective to move toward low-carbon communities, as identified in the Growth Plan. To further support this objective, MMA is encouraged to include requirements that reduce the need for and reliance on air conditioning.
Proposed Plumbing requirements will support the implementation of our water related strategies
York Region is a leader in water conservation and the conveyance and treatment of wastewater. Including requirements for grey-water reuse and instillation of backwater valves in the Ontario Building Code supports implementation of water conservation and inflow and infiltration reduction objectives. York Region staff strongly encourages the Province to consider tools to mitigate the potential impact of building practices on wastewater systems including prohibiting connection of foundation drain collectors and underground parking lot to sanitary sewers. This will become increasingly important to help reduce the risk of sewage bypasses with the onset of more severe storms due to climate change.
Proposed Sustainable Building strategies support implementation of the York Region Official Plan
The York Region Official Plan establishes our commitment to creating sustainable communities. Staff support the proposed changes to Ontario’s Building Code to address indoor air quality, electric vehicle charging stations, and green building standards.
•Indoor Air Quality: Clean indoor air is a key element to sustainable, healthy communities. The proposed changes to Ontario’s Building Code will help implement our policies that guide the creation and continued improvement of healthy communities. To further support healthy indoor air, MMA is encouraged to consider standards and best practices for ventilation as well as require carbon monoxide alarms in additional locations in buildings where combustion sources may be present or introduced.
•Electric Vehicle Charging Stations: York Region is committed to reducing local sources of air pollution. The Ontario Building Code should be amended to require installation of electrical vehicle charging infrastructure for all new commercial, industrial, and multi-unit residential buildings to help meet Ontario’s GHG emission targets.
•Sustainable Building Practices: York Region strongly supports the inclusion of hurricane straps and mandatory backwater valves in houses. These and other measures should be incorporated into future editions of the building code to strengthen the resiliency of all new and existing buildings in Ontario.
York Region staff look forward to the opportunity to continue to work with the MMA on updating Ontario’s Building Code. Please contact Teresa Cline at (905) 830-4444 ext. 71591 or by e-mail at email@example.com should you have any questions or require further clarification regarding the comments provided herein.
Sandra Malcic MCIP, RPP
Manager, Policy and Environment
Long Range Planning
Copy to: Caitlyn Paget, Public Health, York Region
Shahinaz Eshesh, Planning and Economic Development, York Region
Brent Marissen, Environmental Services, York Region
Denis Poncelet, Environmental Services, York Region
TABLE: York Region Comments Regarding the Potential Changes to Ontario’s Building Code Building Commissioning
Functionality and Purpose Considerations
Functionality and purposes of various buildings could differ significantly. There can be buildings of significant size which may have low occupancy/functionality (storage, warehousing, etc.) and relatively low(er) energy consumption and GHG emissions. Potential requirements to increase efficiency of such large buildings may yield minimal net reductions of energy use but at a considerable cost (due to size). A consideration may be evaluating both the size and function of a building in determining potential new requirements.
Building Envelop-Specific Functional StatementsSupports the introduction of two new building envelop-specific function statements.
Recommend requirements that increase energy efficiency and reduce the need for air conditioning, such as:
•External shades on windows;
•Effective, passive ventilation;
•High albedo (cool, reflective) surfaces for the roof, envelope and surrounding site such as parking lots;
•Shared cool rooms inside apartment buildings, to provide air conditioning to protect the health of the most vulnerable people who require active cooling;
•Shared cool spaces outside apartment buildings, to provide shaded, treed spaces with seating as a refuge from overheated apartments;
•Windows that open wide high up to allow ventilation while preventing falls; and
•A program to enable and encourage building managers to utilize the options in the OBC that prevent falls from windows but allow ventilation. The options are found in the current OBC (Section 126.96.36.199 Protection of Openable Windows) and in the Residential Tenancies Act (Section 25 Window Safety Devices). A program could be modelled on that of New York City, which includes an approved list of window guard manufacturers and products. Information on New York City's program is available at: https://www1.nyc.gov/site/doh/health/health-topics/window-guards-faq.page.
Staff support proposal to include loading requirements to provide for solar-ready roofs for large buildings.
Solar-Ready Hot Water System
Staff support proposal to include at least one conduit to facilitate the future installation of a photovoltaic system or a solar domestic hot water system in houses and large buildings.
Staff support proposal to remove of existing exceptions related to insulation and the omission of thermal bridging effects from calculations.
Air Tightness Testing, continuous insulation and fenestration
U-valuesStaff support proposal to include air tightness testing, continuous insulation and fenestration U-values applicable to houses and small residential buildings.
Water and Wastewater
Water Conservation and Wastewater Reduction
York Region seeks to achieve water conservation and wastewater reduction measures through our voluntary Servicing Incentive Program (SIP) and voluntary Sustainable Development Through LEED Incentive Program (LEED) geared towards new residential development. The changes proposed in the OBC supports these initiatives by incorporating new requirements such as grey-water reuse and installation of backwater valve
Staff suggests that the OBC be amended to require water sub-metering. This amendment would support increased enrollment and implementation of water conservation measures through existing incentive programs.
UrinalsStaff supports the clarification of water-use efficiency requirements for urinals. PlumbingYork Region staff are of the opinion that the OBC must ensure plumbing systems are constructed to reduce inflow and infiltration into municipal and regional sanitary sewer systems. Including:
•Technical standards and enforcement tools to ensure that building sanitary sewer tests, bedding, backfill and compaction requirements are met.
•Identify technical specifications for sanitary sewer bedding and cover materials (i.e granular material and not native soils)
•Prohibit the connection of foundation drain collectors to the sanitary sewer under all circumstances
•Require inspection and repair of private laterals prior to commencement of a demolition or renovation project.
Underground Parking Lot
York Region staff suggests that Ministry explore options to disconnect underground parking lots from sanitary sewers to reduce inflow pressure on the system.
Indoor Air Quality
While supportive of the proposed modifications to address indoor air quality, staff recommend additional modifications that go further to improve indoor air quality, including: •ANSI/ASHRAE 62.1, “Ventilation for Acceptable Indoor Air Quality,” https://www.ashrae.org/resources--publications/bookstore/standards-62-1--62-2.
•ASHRAE Indoor Air Quality Guide: Best Practices for Design, Construction and Commissioning, https://www.ashrae.org/resources--publications/bookstore/indoor-air-quality-guide.
•The Well Building Standard (WELL), https://www.wellcertified.com/well. This standard provides guidance which takes a holistic approach public health and safety from 7 dimensions. This can be considered as a resource to inform the building code or a reference tool for proponents to consider best practices.
Radon MitigationExpanding radon mitigation requirements across the province is an important
update. Staff recommend additional modifications in regards to radon:
•More measures need to be taken in addressing potential radon exposure, including making mitigation measures easier for home owners. OBC provisions should include all of the radon protective provisions outlined in Parts 5, 6, and 9 and their corresponding appendices of the National Building Code, 2010 (Reference: pages 29-32 of the CELA report http://www.cela.ca/sites/cela.ca/files/Radon-Report-with-Appendices_0.pdf).
•In addition to including the federal Radon Guideline reference level (currently set at 200 Bq/m3) for all new construction and major renovations, these amendments should also require mitigation if the reference level is exceeded, and requirements that engineers and designers consider radon protection in their designs. For an example see the City of Guelph’s Radon Gas Mitigation Program as a best practice for the OBC provision (http://guelph.ca/city-hall/building-permits-inspections/residential-building-permits/radon/). •Rather than requiring a rough-in for a radon mitigation system at construction, it would be more effective to complete the piping to the exterior for passive venting.
Carbon Monoxide Alarms
Staff recommend the OBC include measures requiring the installation of carbon monoxide alarms. An important consideration is for buildings to have appropriate safeguards during power outages to reduce the possibility of carbon monoxide poisoning resulting from home owners not safely using gas generators and appliances indoors.
Electric VehiclesCharging Stations
Staff support the provision of electric vehicle charging station. To further encourage and facilitate a transition to electric vehicles, the Ministry should consider requiring EV charging infrastructure for all new commercial, industrial, residential homes and multi-unit residential buildings to help meet Ontario’s GHG emission targets. See Electric Vehicles: Reducing Ontario’s Greenhouse Gas Emissions Climate Action Report, https://plugndrive.ca/sites/default/files/Electric%20Vehicle%20-%20Reducing%20Ontario's%20Greenhous e%20Gas%20Emissions%20-%20A%20Plug'n%20Drive%20Research%20Report.pdf.
Green Building Standards
Green Building By-lawsStaff propose the code allow exceptions (or that municipal bylaws require exceptions) for projects that demonstrate higher greenhouse gas emissions from vegetated or white roofing through energy modelling. It should be noted that ASHRAE 189.1-2014 - Section 188.8.131.52 applies to ASHRAE Climate Zones 1, 2 and 3.
SB-10B & SB-12B“Optimum Start Control” is used in SB-10B, Division 3, Sentence 184.108.40.206 (11), but is not defined. We recommend adding a definition for “Optimum Start Control.”
Structural IntegrityStandards for structural integrity should be based on future climatic conditions for all material and components used in the building envelope, roof, and other exterior elements. The Ministry should consider incorporating many of the construction and design guidelines related to extreme weather into the OBC as outlined in the Institute for Catastrophic Loss Reduction Designed for safer living® home program guidelines (see link below) to enable homes to increase their resistance to natural disasters and extreme weather such as high winds, floods, wildfires and severe weather. https://www.iclr.org/images/builders_guide_2010_final.pdf.
Designated Substance Reports
Staff recommends that the Ministry include a requirement for municipalities to require and maintain a copy of a Designated Substances report as part of their demolition permitting process. While there is a regulatory requirement to complete a Designated Substances report prior to demolition under Section 30 of the Ontario Occupational Health and Safety Act, municipalities are not consistently asking for, or retaining, this information when issuing demolition permits. Some municipalities have indicated to us that they do not track this information because it is not required by the Building Code. From a public health perspective, it is important to have this information in the event of an accidental discharge of designated substances to the environment during a demolition.
[Original Comment ID: 211005]
Submitted February 12, 2018 3:39 PM