Re: Agenda Item 9.2 a) VRBA letter (Jane Devonshire)

From: Jane Devonshire Sent: May 1, 2023 6:33 PM To: Info Address info@viewroyal.ca Subject: Please include as correspondence re: Agenda Item 9.2 a) VRBA letter

Dear Mayor and Council,

On reading the letter submitted by C. Edge on behalf of the VRBA under 9.2 a), I had reached out to the members of the Fossil Fuel Non-Proliferation Treaty Alliance (FFNPT) to take a look at this. We have some very qualified people in this group and this is what two of them had to say about our concerns.

From Bruce Murdoch

Bachelor of Commerce with Honours and Certified Housing Professional:

“The reference to radon is not entirely accurate. While Victoria does not require radon mitigation rough-ins, elevated radon levels would be caused by a poor slab seal and possibly exacerbated by inadequate ventilation. Changing from 2.5 Air Changes per Hour in Step Code 3 to 1.5 Air Changes per Hour in Step Code 4 is not a significant change when the slab is properly constructed and adequate ventilation with an HRV is utilized."

He further states:

“New homes have been required to install the infrastructure for radon ever since around 2014 (not sure of exact year). The idea at the time was that if a home exhibited high radon levels, it would be easy to vent soil gasses at a low cost. However, for several years now, new homes are required to complete the soil gas ventilation system. Also added in most munis was a new inspection point to ensure that the basement/crawlspace/slab on grade is sealed off properly under the slab.

To explain the details in new construction:

1. Underslab gravel no longer allows crushed gravel. It requires 6" of large clean rock (we call it radon rock). This allows for a large air pocket under the slab because there are no fine materials in the gravel.
2. When underslab plumbing is done, the plumbing contractor then installs a 4" pipe that terminates with an open end in the middle of the building floor area.
3. After that, it has to have a layer of poly installed (same material as some builders still use for "vapor barrier"). It has to have all joints taped and sealed against the perimeter foundation wall. Soil gas can penetrate a slab hence the need for poly.
4. When the plumber comes back to do the finished plumbing fixtures, they complete the slab ventilation by continuing the pipe out the exterior wall or roof.

So here is how it works: soil gas causes positive gas pressure under the slab as it warms and expands as it rises from the depths of the ground. Because there is a good air pocket under the slab, the pressurized gas will find the easiest exit, which is the open end of that pipe in the middle of the building and it will exit out the wall or the roof by natural depressurization. I measure radon in all our new homes because we live in a high radon area. It works perfectly. If for some reason it wasn't working, the solution is to install an inline fan into the radon pipe and it will suck out all soil gasses. I have never had to do that, even in super airtight homes.

The false part of that letter is that they are measuring elevated radon during the period of time that radon ventilation was not required to be completed, so yes, no doubt radon levels increased in more airtight homes! We are no longer dealing with radon the way it was dealt with pre-2019. Basically, they are telling the truth but not the whole truth so it is effectively a lie.

To clarify something, municipalities can choose to require or not to require radon rough ins, and quite a few don't, particularly in the coastal areas. It is my view that it should be practiced everywhere in the province.

Building officials should understand everything I have written.....they certainly understand it well here in the Kootenays and are sticky about doing it right. If some munis are allowing homes to be built without radon mitigation, they are being irresponsible.”

From Graham Parkinson

“Radon issues are part of my professional background in geophysics and nuclear physics. I have B.Sc.’s and research experience in both, along with working as a Research Associate at the Slowpoke Reactor at the U of A for several years.”

“Firstly, this letter should be responded to about RNG – having a small amount of mostly notional RNG in the natural gas supply is not a “carte blanche” to ignore carbon emissions. And burning RNG produces the same emissions as burning natural gas – they’re the same molecule: methane.

About Radon. As Bruce Murdoch just mentioned in his email, instances of higher radon in well sealed houses is not a failure of the concept of sealing houses. It is a failure in the design and implementation of the required radon mitigation measures that are in the Building Code. If the systems were built as designed with proper quality control, these high radon levels would probably not occur.”

He further states:

“So high levels of radon experienced in newer well sealed buildings are likely the fault of the builders cutting corners, and not doing adequate quality control on radon mitigation during building. The high levels of radon are likely not due to adoption of better house sealing in the Step Code. Having just built a cabin on a local island, we tried to get builders to take things like sealing seriously. I found that they typically don’t bother with things that they don’t think are important in “getting it done” (like foundation sealing for radon, or even proper draft sealing of a house).

Happy to talk about the radon issue more if you’re interested. Basically radon is formed where there are igneous rocks high in Uranium, Thorium or Radium (or in some cases, where Uranium has concentrated in sedimentary basins). Radon is a volatile gas that can seep into basements and crawl spaces if they are not well sealed off from the soil, and if the gravel foundation layer is not properly vented to dissipate radon away from the building, out into the air.”

Hope this helps to address some of the concerns that were raised in the VRBA letter.

Respectfully yours,

Jane Devonshire Member of the FFNPT Alliance whose members are the South Island Climate Action Network, the Nanaimo Climate Action Hub, Stand.Earth, Force of Nature Alliance, Okanagan Climate Hub, East Kootenay Climate Hub, and Penticton First Things First.