Prepared June 2023
Thanks for agreeing to tell the government whatever about building codes. This document will help you put together a letter! Choose which reasons for higher energy tier adoption, grab the sample text, and customize it to personalize your letter.
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DEADLINE FOR COMMENTS: MONDAY JUNE 26th 2023 11:59 PM - more info here
Government background document - (Click on Policy Objectives > Scroll way down to "Background Context" #4 "Energy Efficiency")
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Saves homeowners money on energy bills and retrofit costs
Timeline gets slowed down when we start at Tier 1
Competitive Advantage Working Between Provinces
Currently building at Tier 2 & 3 - Manitoba Is Not New to Building Better
Save money in the life cycle and pay less carbon tax
Building Comfort Impacts for Learning and Productivity
Incremental Building Costs Between Tiers is Negligible
Commercial is starting at Tier 1 is not a problem
Added costs and capacity to continuously train
Trained Energy Advisors Ready To Go… for now
Future-Proofing our Building Stock & More Financial Savings
Help Meet Municipal Climate Targets
Supply Chain & Costs of Materials Not a Concern
Preference is not what should be prioritized
Consultation Process - Need a Working Group
Even Chat GPT Recognizes that we should not be adopting a lower Tier
Training and Skill Development:
Increased Demand for Energy-Efficient Products:
Technological Innovation and Job Creation:
Provincial Leadership and Global Competitiveness:
Learn more background on building codes in Manitoba here:
https://www.sustainablebuildingmanitoba.ca/manitoba-building-codes-and-standards/
Who are you?
It is always good when the government understands where you are coming from with your arguments. Are you a tradesperson? A designer? A homeowner? A concerned citizen?
Sample text
Hi my name is _______ and I have experience with ___________ because I...
(say who you are and why you care)
REASONS
Saves homeowners money on energy bills and retrofit costs
While concerns about added housing costs are valid, the actual increase in costs between energy efficiency Tiers is relatively low. It is important to consider the long-term benefits and savings associated with higher energy efficiency Tiers. While there may be a modest increase in costs when building to higher Tiers, the potential savings over time can be substantial for homeowners. Energy-efficient homes typically have lower utility bills, reducing long-term operating costs. Additionally, energy-efficient homes may qualify for incentives, rebates, or lower insurance premiums. Therefore, while there may be some upfront investment, the financial benefits and energy savings over the lifespan of the home can outweigh the initial costs, making it a worthwhile investment for homeowners.
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The increase in construction costs between Tier 1 and Tier 2 is generally negligible. The increase between Tier 2 and Tier 3 may be slightly higher, around $4000 to $5000, which will be recouped over time through energy savings and by avoiding future retrofit costs. Considering the overall cost of the house, an additional 2% investment in energy efficiency measures is relatively small, especially when considering the long-term benefits and savings for homeowners. It is important to recognize the value of these investments in terms of improved energy efficiency, reduced utility bills, and enhanced comfort and sustainability.
Consumer Protection Ensured
Consumers are protected from purchasing or renting buildings that are inefficient and would result in higher energy bills. Energy efficiency building codes promote healthier and more comfortable living spaces while reducing environmental impact, ultimately benefiting consumers in terms of reduced energy costs and improved overall quality of life.
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Energy-efficient building codes are a consumer protection issue because they ensure that new homes meet certain energy efficiency standards. These codes establish minimum requirements for insulation, HVAC systems, lighting, and more. By enforcing these standards, consumers are protected from purchasing homes that are inefficient, leading to higher energy bills and environmental impact. Energy-efficient building codes promote transparency, reliability, and long-term cost savings for consumers, creating a healthier and more sustainable built environment.
Protect the Grid
In Manitoba, energy efficiency measures play a vital role in protecting the electrical grid. By reducing overall energy consumption in buildings, homes, and businesses, energy efficiency helps to lower the demand on the grid during peak times. This reduces the strain on grid infrastructure, minimizing the risk of overloads and blackouts. Energy-efficient buildings and appliances in Manitoba help to manage the demand for electricity, ensuring a more reliable and stable supply. Additionally, energy efficiency measures can contribute to lowering the province's overall electricity consumption, allowing for better optimization of existing resources and supporting the integration of renewable energy sources into the grid. This enhances grid resilience, reduces the need for costly infrastructure expansions, and promotes a sustainable energy future for Manitoba.
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Energy efficiency measures in Manitoba not only help reduce electricity consumption but also optimize the use of existing resources. By lowering overall electricity demand, the grid can operate more efficiently and effectively. This allows for better integration of renewable energy sources, such as wind or solar, into the grid. With reduced electricity consumption, the need for costly infrastructure expansions can be minimized, resulting in cost savings for both the utilities and consumers. Ultimately, energy efficiency supports a sustainable energy future for Manitoba by reducing greenhouse gas emissions, enhancing grid resilience, and promoting the responsible use of energy resources.
Better Indoor Air Quality
We see what’s happening outside. The pandemic. The importance of good indoor air quality has never been more evident. Energy-efficient ventilation systems can help remove indoor pollutants more effectively, enhancing the overall air quality. Improved insulation and airtightness in energy-efficient buildings can prevent the infiltration of outdoor pollutants, further enhancing indoor air quality.Occupants can enjoy a healthier and more comfortable living or working environment, leading to increased satisfaction and productivity.
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Indoor air quality has never been more relevant. Energy-efficient ventilation systems remove indoor pollutants effectively, while improved insulation prevents the entry of outdoor pollutants. This enhances indoor air quality, promoting a healthier, more comfortable environment that boosts satisfaction and productivity for Manitobans.
Timeline gets slowed down when we start at Tier 1
We know we need to get to Net Zero, and we know we need to get there fast. Starting at the bottom (Tier 1) slows down the timeline.
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Defaulting to start at Tier 1 adds months or years onto the timeline for Manitoba to get to net zero. I implore you to recognize the reality of the climate crisis, especially with all the recent wildfires, to recognize that Manitoba is ready for Tier 2, and to start us there so we can more quickly to net zero building.
Competitive Advantage Working Between Provinces
Building professionals routinely provide technical services both within and outside of Manitoba. Ontario, for example, has committed to adopting at Tier 3, so if Manitobans lack experience building at this tier, they will be at a disadvantage when bidding for work in Ontario. If other provinces adopt a lower tier than Manitoba, it is much easier to remain competitive in that scenario than it is with provinces that adopt a higher Tier.
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I am not concerned about provinces that adopt a lower Tier than Manitoba does as our workforce will have the skills to work in those jurisdictions. As a Manitoba company, I will be at a disadvantage for work outside of MB because my workers will have less experience building at a higher Tier. Yes, I could invest in proficiency in multiple Tiers so that I can work outside the province, but it is a drain on my resources that again, reduces my capacity to compete. Also, if we wait too long to adopt a higher energy efficiency tier, other companies who have been working in the new code already will have an advantage against me for getting work in my own province!
Lower GHG Emissions
"Tier 1 for residential/small buildings would not represent a notable energy efficiency improvement." - MB Regulatory Consultation Portal.
Improving energy efficiency will reduce the amount of natural gas required for heating, and the amount of electricity required for cooling. This will reduce Manitoba’s GHG emissions and extend the ability of our existing hydroelectric facilities to meet future demand.
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I am very concerned about climate change and a more energy efficient building emits less greenhouse gas emissions. The production of building materials and the construction process already creates more GHG emissions, but more importantly – new buildings also continue to emit through their decades-long life cycle. The less energy we need to heat and cool these new buildings – the more feasible our GHG reduction targets become. Time is of the essence and starting at Tier 1 does not reflect the urgency of climate change.
Currently building at Tier 2 & 3 - Manitoba Is Not New to Building Better
Manitoba used to show ambition— we were a national leader in energy efficiency. Even though our province has been stuck on the 2011 Codes for over a decade and missed adopting the 2015/17 codes, that ambition meant that we are consistently building what is now considered Tier 2 and Tier 3 houses. These results have been assessed by trusted, locally operating NRCan licensed Service Organizations. Why would we step back?
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This decision does not reflect that Manitoba is already building many Tier 2 and 3 Part 9.36 buildings. These builders will most likely not change what they are building. However, starting at the lower Tier add steps and time to the pathway to Net Zero. The code plays a critical role in raising the bar for the benefit of all Manitobans. It will not be difficult for every builder to thrive at Tier 3.
Incentive Programs Impaired
Manitoba Hydro and more recently Efficiency Manitoba have long provided incentive programs to encourage buildings to exceed the minimum requirements. Municipalities are also able to create programs that incentivize builders to design and build above minimum code requirements. Tenured local program administrators have provided feedback that even before optimization analysis is carried out, the majority of Manitoba new homes have starting designs consistent with Tier 2. By adopting Tier 1 and delaying the adoption of higher Tiers, programs like the New Homes Program will be impaired in upgrading their own minimums, paying incentive and rebate dollars to projects that are no more energy efficient today than they would have been if built ten years earlier. Additionally, the province, vis a vis Efficiency Manitoba, will be delayed in claiming the significant energy and GHG emissions savings associated with higher Tier codes.
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We have already shown that we can do it. For decades, we have been designing and constructing new buildings to much higher levels of energy efficiency through voluntary provincial rebate programs, provincial government Green Building Policies, and through actions of local builders, trades, and designers who have upskilled in pursuit of more efficient practices and products for their customers. There is no reason to delay a higher Tier adoption when we have proven that we already design, build, and commission more energy efficient buildings and can do it for almost the same cost as buildings with minimum specs.
Save money in the life cycle and pay less carbon tax
When considering the total cost of building ownership, including the cost of energy and maintenance over the entire lifecycle of a building, and not just the upfront cost. Canadian buildings are expected to last for 50 years or more. New buildings constructed to stringent building energy codes help avoid locking in decades of inefficient building performance. Building to higher performance standards today means building owners can avoid costly and complex retrofits in the coming years – there are substantial savings which can be realized by adopting a higher energy efficiency Tier and to mandate building higher performing buildings which will save the owner money over the long term by reduced utility bills and carbon tax payments. Building to a higher Tier now will save money.
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Investing in energy efficiency at the outset for new buildings is the most cost efficient strategy. If we do not mandate more energy efficient buildings now, all Manitobans will pay more for energy through the life of the building – especially as the carbon tax increases. This will be a drain on our economy for decades to come whereas investing in more energy efficiency now is a driver for our economy and new green jobs. More and more I am facing increasing energy costs. I would like to make sure we are doing everything we can to keep the ongoing costs low and you have an opportunity to keep more money in the pockets of Manitobans. We need to stop thinking short term and look at the long term effects of our decisions.
Building Comfort Impacts for Learning and Productivity
The thermal comfort impact of the indoor environment is easily understood by anyone who has tried to concentrate to learn or work while sitting next to a drafty window on a cold winter day. Each successive Tier improves the minimum performance of building enclosure assemblies and thereby improves occupant productivity and learning outcomes. Building to 2020 codes will improve building performance, and thus human comfort. It should be noted that COVID will most certainly not be the last pandemic we will see. Building higher performing envelopes that are more airtight will facilitate a properly controlled and operational HVAC system.
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Whether at home, work or school, I and other Manitobans deserve to be comfortable and a high performance building is important. We all know what it is like to be in a drafty building and how distracting it can be. The higher energy efficiency Tier will go further in ensuring that comfort is achieved. I also think about the resale value of the building when it comes to new builds. As well, I would like Manitoba to be better prepared with regards to air quality when it come to the health of people living and working in buildings – building higher performing envelopes that are more airtight will facilitate a properly controlled and operational HVAC system.
Incremental Building Costs Between Tiers is Negligible
Complying with Tier 2 energy efficiency requirements may incur upfront costs of a few hundred dollars, which is a small fraction (less than 0.05%) of the total cost of a new home. Investing in improving the building envelope and airtightness can significantly reduce uncontrolled air flow and heat loss. As a result, the heating and cooling equipment required for the building can be downsized, leading to not only more affordable capital costs but also long-term reductions in energy consumption. This translates to lower energy bills for heating and cooling throughout the entire lifespan of the building, making it a cost-effective and sustainable choice for building owners. Tier 3 has a greater additional cost because energy models are required.
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Using cost as a reason to not go straight to a higher Tier does not make sense to me as the difference in costs between the tiers is minimal. I know that costs are always a concern and I do not believe that in this case we should see this as a reason to not move forward. Especially when you consider how much money will be saved in reduced energy bills and not having to do a retrofit of your home.
Tier 1 - Additional insulation and more efficient air conditioner: less than $1000 additional costs
Tier 2 - added air tightness test and additional materials: around $1000 additional costs
Tier 3 - required energy model and additional materials: between $4000 and $5000 additional costs. Note: air tightness testing is provided and energy modelling fees are rebated as part of Efficiency Manitoba’s New Homes Program, effectively reducing costs to Tier 2 levels for participating builders.
Quality Control Heightened
At Tier 2 an air tightness test is added which provides an important benefit to ensure the quality of the build.
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Homebuyers need to trust that they are purchasing a quality home - critical given that a house is one of the biggest purchases or most people’s lives. Making sure that there is an air tightness test confirms that the home is or is not energy efficient. An energy efficient home saves the homeowner money on energy bills, which are projected to go up for a multitude of reasons.
Commercial is starting at Tier 1 is not a problem
On the commercial side Manitoba is starting at Tier 1. This should have no impact on where the residential side starts since people tend to work either in commercial or in residential. It is very normal for a province to be on different Tiers for each.
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Commercial and residential tiers do not need to be the same. There are different skills for each code set and different people tend to work on one or the other so having commercial start at Tier 1 is no reason for residential to start there also. It is still my hope that Manitoba will move quickly up the Tiers for both sets of codes.
Added costs and capacity to continuously train
Adopting a lower Tier as a starting point can impose additional challenges and costs on architecture, engineering, and building professionals. With each new Tier introduced, there is a need for additional training and familiarization of staff, as well as the development of new designs and specifications. Starting at a higher Tier can help mitigate these challenges, as it allows professionals to incorporate energy efficiency measures from the outset, reducing the need for significant adaptations and retraining with each subsequent Tier. This approach can streamline the process and minimize overhead costs associated with adapting to evolving energy efficiency requirements.
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I am very concerned about the added financial cost and time spent on training that will arise from going through each new tier rather than straight a higher tier. It is asking a lot of firms and professionals to put that kind of energy into learning new details for each new tier as Manitoba moves toward net-zero builds. It is more efficient financially to adopt a higher energy efficiency Tier now.
Trained Energy Advisors Ready To Go… for now
In response to the shortage of Manitoba energy advisors a few years ago, a training program was developed, successfully training cohorts of advisors. However, current demand for their services is decreasing.Tier 3 requires energy models that can be done by these certified energy advisors.
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The trained Manitoban energy advisors are currently prepared for work. However, to prevent potential workforce loss to other industries, it is crucial to provide them with steady employment. Their expertise in measuring and modeling home energy use will be essential for Tier 3 compliance and energy modeling of new homes. Failure to secure their services may lead to delays in construction projects.
Future-Proofing our Building Stock & More Financial Savings
Energy efficiency requirements are expected to become more stringent over time. Building to lower-tier standards may pose risks in the future, as these buildings may be regarded as sub-standard and require extensive retrofits to meet updated standards. By anticipating future regulations and building to higher-tier standards from the outset, owners can avoid potential costs and disruptions associated with retrofits and ensure their buildings remain compliant and energy-efficient in the long run. Taking a proactive approach in construction helps future-proof buildings and mitigates the risk of falling behind evolving energy efficiency standards.
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Building to lower-tier energy efficiency standards may lead to future risks, as regulations are expected to become more stringent. By proactively building to higher-tier standards, owners can avoid costly retrofits and ensure long-term compliance with evolving energy efficiency requirements. The cheapest time to build to high energy efficiency standards is during initial construction.
Reducing Waste
Right now homeowners are going to buy the house with the set of windows that it comes with and then in a few years later, they will need to buy a new set of windows to reduce their energy consumption and meet energy efficiency standards.
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I would like you to consider the waste that will be associated with the needed retrofits from starting at a lower Tier. For example, why are we asking homeowners to buy multiple sets of the same thing? First they will buy the windows that come with the house. Then, in a few years, they’ll need to buy a second set at a higher level of energy efficiency to reduce consumption and meet energy efficiency standards. This can all be avoided by starting with higher energy efficiency standards that require the installation of energy-efficient windows from the beginning and thus we can avoid the need for homeowners to purchase multiple sets of windows and reduce the associated waste and costs of retrofitting in the future.
An energy-efficient building also minimizes construction waste by utilizing sustainable materials, implementing efficient construction practices, and maximizing resource utilization, thereby reducing the amount of waste generated during the building process.
Help Meet Municipal Climate Targets
Energy efficiency tiers serve as a crucial tactic for municipalities in Manitoba to achieve their climate targets. By implementing these tiers, they can promote sustainable development and reduce greenhouse gas emissions in buildings.
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The City of Winnipeg’s Community Energy Investment Roadmap states “Starting in 2022, retrofit 100% of all existing dwellings built before 1980 by 2035, in order to improve thermal and electrical efficiency by 50%. Starting in 2035, retrofit 100% of all remaining buildings…”. The Dunnottar Climate Change Local Action Plan recommends having “an energy audit conducted for your home and implement the recommendations” as part of its strategy to address the 44% of GHG emissions from residences. Adopting above Tier 1 sets them on a path to success. We do not live in a province where they can select their own tier so it comes down to the actions of the province here.
Northern Manitoba Benefits
Northern Manitoba, with its low temperatures and challenges in existing building stock, is a prime area where buildings need to be highly energy efficient. High energy bills in this region pose a significant problem. By adopting a higher energy efficiency tier, there is an opportunity to address and prevent the expansion of this issue. Implementing more stringent energy standards can help improve the energy performance of buildings in Northern Manitoba, reduce energy consumption, and alleviate the burden of high energy costs for residents and businesses.
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The province-wide impact of the energy efficient tier selection is crucial. In Northern Manitoba, where extreme low temperatures prevail, energy efficient buildings hold great potential. Addressing the housing issue requires highly energy efficient new builds, which can be ensured through a higher tier implementation.
Affordable Housing Supported
Housing cannot be considered affordable if it is not energy efficient.
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Considering the impact on low-income Manitobans is essential, particularly with the rising cost of energy. Affordable housing must prioritize energy efficiency to ensure affordability in the long run, as energy costs play a significant role in housing affordability.
Supply Chain & Costs of Materials Not a Concern
In recent years, there were reported supply chain issues within the industry, but it is reassuring to know that they have been resolved. Strengthening the supply chain to ensure the availability of energy-efficient materials within the province can have a positive impact on cost reduction. With a more accessible supply of such materials, the costs associated with implementing energy-efficient measures can be lowered, benefiting everyone involved in the construction and renovation processes.
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According to industry reports, there are currently no supply chain issues for energy-efficient building materials. As the demand for these materials increases, it is expected that costs will go down in the region due to economies of scale and increased production, benefiting consumers and promoting further adoption of energy-efficient practices. This is a critical piece that will enable the much needed expansion of retrofits.
Default Tier Makes no sense
Government’s Background and context says that:
“This proposal adopts the default Tier 1 under the building and energy codes, recognizing that further engagement is needed to develop a roadmap to adopt higher tiers.”
Preference is not what should be prioritized
Government’s Background and context says that:
“Consulted stakeholders mostly advocated starting at higher Tier 2 or 3 for housing/small building energy efficiency requirements under the NBC, but homebuilders identified a preference to start at Tier 1…”
Consultation Process - Need a Working Group
Having a clear pathway to attain the highest energy efficiency tier for residential buildings is important. However, the province's red tape reduction initiative led to the shutdown of the working group that played a role in guiding the adoption of energy efficiency codes..
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Having a collaborative approach with diverse stakeholders is crucial for effective implementation of energy efficiency initiatives. Establishing a Manitoba task force with clear terms of reference and transparent actions is important. A refreshed mandate can include developing a plan to progress through higher tiers and supporting its implementation. Secretariat support from the province's Chief Building Official is essential, highlighting the importance of filling and maintaining that position to ensure smooth operations and coordination.
Even Chat GPT Recognizes that we should not be adopting a lower Tier
Benefits of Energy Efficient Building.
Economic Benefits:
Energy-efficient buildings can lead to long-term cost savings for occupants through reduced energy bills. Additionally, the implementation of energy efficiency tiers can contribute to overall economic growth by attracting investments, promoting innovation, and supporting local businesses involved in the construction and retrofitting of buildings.
Environmental Impact:
Buildings account for a significant portion of global energy consumption and greenhouse gas emissions. Energy-efficient building codes can help reduce the energy demand and carbon footprint associated with buildings. By incorporating energy-efficient design principles, such as insulation, efficient HVAC systems, and renewable energy technologies, buildings can consume less energy and contribute less to climate change.
Job Creation:
The implementation of energy efficiency tiers will likely create new job opportunities in the construction industry. As buildings need to be retrofitted or constructed to meet the new energy efficiency standards, there will be a demand for skilled workers in areas such as insulation installation, HVAC systems, and energy audits.
Training and Skill Development:
To meet the requirements of energy efficiency tiers, workers in the building sector will need to update their skills and knowledge. This could lead to increased training programs and educational opportunities for workers to learn about energy-efficient construction techniques and technologies.
Increased Demand for Energy-Efficient Products:
The implementation of energy efficiency tiers may result in an increased demand for energy-efficient products, such as energy-efficient windows, appliances, and building materials. This would stimulate growth in manufacturing sectors related to producing these products, potentially leading to job creation in those industries as well. For example, Manitoba has a thriving windows manufacturing sector.
Industry Leadership:
Organizations that adopt higher tiers and prioritize advanced training demonstrate leadership in energy-efficient construction practices. They position themselves as forward-thinking and aligned with sustainability goals, which can attract environmentally conscious clients, projects, and partnerships.
Energy Cost Savings:
Energy-efficient buildings consume less energy for heating, cooling, lighting, and other operational needs. As a result, occupants of these buildings benefit from reduced energy bills. Additionally, energy-efficient buildings often have a higher resale value and lower maintenance costs, making them economically advantageous in the long run.
Long-Term Cost Savings:
While there may be initial upfront costs associated with implementing energy-efficient measures, the long-term benefits outweigh them. Energy-efficient buildings tend to have lower operational costs, reduced maintenance expenses, and increased property value. Over time, the energy savings can outweigh the initial investment, resulting in significant cost savings.
Energy Security:
Energy-efficient buildings contribute to enhancing energy security by reducing reliance on external energy sources. By optimizing energy consumption within buildings, countries can reduce their dependence on imported energy and become more self-sufficient. This can enhance resilience in the face of energy price fluctuations, supply disruptions, or geopolitical uncertainties.
Building Performance:
Enhanced energy efficiency standards promote better building performance overall. Buildings constructed to higher energy efficiency standards tend to have improved thermal comfort, indoor air quality, and durability. These factors contribute to occupant satisfaction, health, and productivity.
Health and Comfort:
Energy-efficient building codes often prioritize factors such as indoor air quality, thermal comfort, and natural daylighting. These elements can significantly improve occupant comfort, productivity, and overall well-being. Proper ventilation, insulation, and moisture control measures also contribute to reducing indoor air pollutants and preventing the growth of molds, thereby promoting a healthier living or working environment.
Technological Innovation and Job Creation:
The implementation of energy-efficient building codes can drive technological innovation and stimulate the green economy. It encourages the development and adoption of advanced building materials, energy-efficient appliances, renewable energy systems, and smart building technologies. This, in turn, can create new job opportunities in sectors such as construction, manufacturing, engineering, and renewable energy.
Provincial Leadership and Global Competitiveness:
By adopting and enforcing stringent energy-efficient building codes, a region or country can showcase its commitment to sustainability and environmental stewardship. This positions them as leaders in the global transition towards a low-carbon economy. It also attracts businesses, investors, and residents who prioritize sustainable practices and can contribute to economic development.
Reduced Training Rounds:
Training workers to meet higher standards right away reduces the need for subsequent rounds of training when higher tiers are adopted in the future. This can save time, resources, and minimize disruptions to ongoing construction activities.
Enhanced Employability:
Workers trained to meet higher energy efficiency standards are equipped with valuable skills and knowledge. This can make them highly employable in the construction industry, as there will be a growing demand for workers with expertise in energy-efficient building practices. This benefits both the workers and the industry as a whole.
Overall, adopting energy-efficient building codes is essential for mitigating climate change, reducing energy consumption, improving occupant comfort and health, fostering innovation, and achieving long-term economic and environmental sustainability.
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