January 17, 2020 Energy…

January 17, 2020

Energy Efficiency Standards Team
Ontario Ministry of Energy, Northern Development and Mines
159 Cedar Street
Sudbury, ON P3E 6A5

Re: Proposal to amend Ontario's energy efficiency regulation

Dear Energy Efficiency Standards Team,

These comments are provided by Fenestration Canada in response to the low-rise residential windows regulation prepared by the Energy Efficiency Standards team of the Ontario Ministry of Energy, Northern Development and Mines.

Fenestration Canada is an industry association comprised of manufacturers of windows, doors and skylights, including their material suppliers and providers. Our Association has nearly 220 member companies from across Canada, the United States, and abroad.

We stand ready to work with you on this important regulation and offer the following recommendations and comments for your consideration:

a) Enforcement is a major concern.
i. Enforcement of the Ontario Electricity Act, 1998 with respect to fenestration (Schedule 8) has been nonexistent.
ii. If the regulations are to be enforced, additional details are needed outlining how that will be done.

b) The current SB-12 allows up to 1.8 U-factor and this is in conflict with the proposed 1.61 U-factor. How will you reconcile the conflict between the two?
i. The adoption of a new energy regulation that exceeds SB-12 requirement would create a lot of confusion regarding building code and energy efficiency compliance, given that code requirements are enforced by building officials and the Electricity Act is not enforced.

c) Renovations are an area of concern.
i. Building permits are expected to meet all of the building code and regulatory requirements.
ii. Building permits may not be required if the size of the openings are not changing. How will the regulations be enforced for non-permitted projects?
iii. This could create an incentive for installers who are not pulling permits to provide non-compliant products.

d) In light of the fact that doors are not included in this regulation, the wording "decorative sidelights for doors" is confusing and should be removed.

e) We are concerned that the use of the Energy Rating (ER) path in the regulation could have unintended consequences if additional guidance is not provided to consumers. At any regulated energy performance level, products that comply on the basis of ER have higher solar heat gain characteristics than products that comply on the basis of U-value, and at any regulated performance level they are less expensive. Use of high solar gain windows has been problematic in Ontario, particularly in new homes with higher window-to-wall ratios facing South and West. High solar heat gain windows are generally desirable to reduce winter heating demand, but when windows are larger and mainly face South or West, high solar gain windows have been associated with significant overheating discomfort and greater use of air conditioning. Because it is easier for consumers to select less expensive windows, ER-qualified windows are often bought and sold without consideration for the future comfort of the occupants.

In closing, Fenestration Canada appreciates the excellent work of the Ministry in developing these regulations. We fully understand it is difficult to construct the regulations to fully meet all stakeholder’s needs but we appreciate the careful considerations of our recommendations.

Terry Adamson
President
Fenestration Canada

Stéphane Labelle
Executive Director
Fenestration Canada

Al Jaugelis
Technical Director
Fenestration Canada