Re: Zero Carbon Step Code: New Implementation Approach and Bylaw

Community Builders… Building Communities

April 21, 2023

Mayor Dean Murdock and Council District of Saanich 770 Vernon Ave, Victoria, BC V8X 2W7

Dear Mayor and Council,

Re: Zero Carbon Step Code: New Implementation Approach and Bylaw

Renewable Natural Gas (RNG) obtained from the Hartland Landfill project should be included in the Zero Carbon Step Code policy. The CRD says, “RNG is a carbon-neutral energy made from capturing and upgrading the biogas released from decomposing organic waste in the landfill.”

As a carbon neutral energy source for heat, RNG would be similar to electricity. However, municipalities are fast-tracking to Step Codes 4 & 5 if RNG is used. These levels add tens of thousands of dollars to the cost of a home – costs already significantly boosted by higher interest rates for homebuyers. BC has the highest average housing costs in Canada - $960,067 according to the Canadian Real Estate Association.

The Saanich report says, “The approved Council direction does not require any further accelerated implementation of the BC Energy Step Code…” Does this mean Saanich will not require higher levels of the BC Step Code when RNG is used?

BC’s Ministry of Housing says, “The local authority decides the Energy Step and Carbon Level required for new construction.”

There should be no elevated levels of Step Code required for RNG, beyond the provincially mandated Step Code 3. VRBA has regularly advised municipalities to avoid higher steps of the BC Step Code, which may create unintended consequences, such as toxic radon.

The Canadian Association of Radon Scientists and Technicians recently held their annual conference in Victoria. It was noted radon levels have been increasing in more energy efficient homes. Higher radon levels were found in homes built from 2012 to 2021 compared with those built in 2001 to 2010, after which the building code increased energy efficiency. Reasons for more radon include house depressurization and gaps from concrete slab shrinkage.

A presentation by a National Building Code representative said their radon task group found radon maps lack sufficient detail to determine radon levels. Radon maps are unreliable because radon is site specific and can only be reliably tested after the home is built. Therefore, radon mitigation rough-ins are necessary.

Six years ago (2017), the BC government enabled municipalities to fast-track energy efficiency via the BC Step Code without this radon research. Saanich and other municipal councils boosted the Step Code from Step 1 to Step 3, bypassing Step 2 against the advice of VRBA. This may create health risks, including lung cancer and leukemia, especially for children and seniors, even at lower radon levels, over extended periods of time.

Municipalities do not possess the expertise nor resources to do the necessary research for health and safety in buildings. VRBA recommends following the National Building Code and BC’s provincial timeline of 2030 for decarbonization and 2032 for Step Code 5/net zero ready.

If you require more additional information, feel free to contact me.

Sincerely,

Casey Edge Executive Director

cc CRD municipalities