Correspondence: Victoria Residential Builders Association regarding BC Step Code

Subject: FW: CRD Meeting re Accelerating BC Step Code to Tiers 4 & 5

Dear Mayors, Chairs and Councils,

We have been contacted by the CRD to attend a “Solutions Lab” on April 20th to accelerate the BC Step Code to Tiers 4 & 5.

Attached is our letter declining to participate in fast-tracking the building code, an initiative for which they are not qualified.

Major changes to the building code should be addressed only by Codes Canada using the expertise and resources of the National Building Code committees.

I have spoken directly with CRD representatives regarding our position.

regards,

Casey Edge Executive Director Victoria Residential Builders Association #1-3690 Carey Rd Ph: 250-383-5044 vic.builders@vrba.ca www.vrba.ca www.careawards.ca

April 12, 2022

Matt Greeno, Community Energy Specialist Capital Regional District 625 Fisgard Street, Victoria, BC V8W 2S6

Dear Mr. Greeno,

Re: Solutions Lab to Accelerate Step Code in the CRD

The Victoria Residential Builders Association will decline to attend the CRD’s “ Solutions Lab” to “accelerate implementation of higher steps of the Step Code.” The BC government plans to make Step Code 3 mandatory by year-end. Fast-tracking the BC Step Code beyond this level only undermines consumer protection and housing affordability. Numerous flaws in the BC Step Code have been discovered including:

• Lack of research into toxic radon issues and mitigation in energy efficient homes. Radon levels exceeding the maximum established by the World Health Organization have been detected in Victoria;
• No prescriptive path to address high modeling costs and no mandatory Step Code education;
• Wildly inaccurate cost estimates and dysfunctional energy efficiency metrics;
• Net-zero is achievable at Step 4 making BC’s costly Step 5 unnecessary adding to unaffordability.

Much of this information was revealed by the National Building Code’s due diligence. BC Step Code’s significant flaws undermining both consumer protection and affordability are the direct result of “accelerating” energy efficiency in BC’s Building Code.

The Solutions Lab is at the “direction” of several councils to “accelerate implementation of higher steps of the Step Code.” Municipalities do not possess the expertise, experience nor resources to do the necessary research and diligence for major code changes to ensure health and safety.

Codes Canada recently released energy efficiency changes in the National Building Code including a prescriptive option to address affordability. However, Codes Canada has not completed research on very high Step Code levels proposed by the CRD’s “Solutions Lab.”

VRBA continues advising municipalities to wait for the BC government to establish mandatory levels of energy efficiency combined with education rather than use local bylaws to fast-track energy efficiency. A local “Solutions Lab” does not replace National Building Code expertise, research and due diligence.

If you require more additional information, feel free to contact me at 250-383-5044.

Sincerely,

Casey Edge Executive Director