Enbridge submission for…

Enbridge submission for Transforming and Modernizing the Delivery of Ontario’s Building Code Services (ERO 019-0422)

Enbridge supports the Government of Ontario’s objective to consider modernizing the delivery of Ontario’s Building Code (OBC) Services and believes that we can contribute to this effort through our commitment to safety in delivering energy and its effective usage in new building development. We are pleased to provide the following comments in response to the Ministry of Municipal Affairs and Housing (MMAH)’s request for 2019 consultation referring to the “Transforming and Modernizing the Delivery of Ontario’s Building Code Services” Discussion Paper.

Enbridge Gas Inc. is Canada's largest natural gas storage, transmission and distribution company based in Ontario with a more than 170-year history of providing safe and reliable service to customers. The distribution business serves about 3.7 million customers, heating over 75 per cent of Ontario homes. Since 1995, Enbridge’s natural gas conservation programs have helped customers reduce their energy consumption by 30%—this is the equivalent of removing 7 million cars from the road. Enbridge’s storage and transmission business offers a variety of storage and transportation services to customers at the Dawn Hub, the largest integrated underground storage facility in Canada and one of the largest in North America. Enbridge Gas Inc. is owned by Enbridge Inc., a Canadian-based leader in energy transportation and distribution.

During the Government of Ontario’s Regional Information Session hosted this fall, the MMAH identified seven key reasons for the need of change to transforming service delivery. One reason was regarding recent building failures from visible structural insufficiencies that threatened public health and safety. This example highlights the need to improve the current system related to professional competency. Over time, the OBC has come to include other aspects of building design and operation such as building energy usage, equipment Minimum Energy Performance Standards (MEPS), and carbon emissions, where failure is less evident to recognize or measure and therefore difficult to diagnose poor guidance. Enbridge has considerable experience and expertise in energy systems, their safe and effective use, and comparison.

Enbridge recommends two actions that would help ensure a transparent code development process, uphold professional competency of OBC users or administrators, and enable the review of new technologies:
• Enbridge recommends the inclusion of technical committees that incorporate appropriate industry experts – including Enbridge representation and expertise in energy systems – in order to provide guidance regarding the accuracy of code development. A transparent process with means for public access to the source information for code changes would also allow reasonable public and professional understanding and review. For code technical changes that impact on gas installation, the Ministry is encouraged to undertake a concerted effort to align these reviews with other appropriate authorities having jurisdiction, e.g. Technical Standards and Safety Authority (TSSA), Electrical Safety Association (ESA).
• To promote a transparent, informed and responsive process to changes in the building sector, Enbridge recommends the creation of a committee (technical and interested parties) or process that allows builders, developers, homeowners and localized building code professionals (interested parties) to submit new building concepts and technologies along with proposals identifying existing barriers in the building code and proposed changes for review. The purpose for this committee would be to ensure the Ontario Building Code remains responsive, relevant, transparent, unbiased, and continues to address evolving public safety issues, and supportive of technology innovations.

We commend the Ministry for continually looking for ways to improve its building sector supports. As the largest natural gas utility in Ontario, Enbridge plays a vital role in providing energy infrastructure to service the energy building requirements for most Ontarians. Evolving and new technologies that promote safety and energy efficiency are also core to what we do. To fulfill this role, Enbridge is engaged in several key phases of the building construction process that relies on building code guidance. This entails interactions and coordination across a wide range of professionals, trades, developers and customers.

Conclusion
Robust building code development and implementation processes pave the way for seamless building code administration and enforcement. Enbridge appreciates the opportunity to provide input on the Government of Ontario’s efforts for transforming and modernizing the delivery of Ontario’s Building Code services and we welcome opportunities to discuss these matters further. If you have any questions or require additional information please do not hesitate to contact Brad Lattanzi, Government Affairs Strategist (brad.lattanzi@enbridge.com).