VRCC response to Item 9.2 a) - Zero Carbon Step Code

From: Jane Devonshire Sent: May 1, 2023 6:50 PM To: Info Address info@viewroyal.ca Subject: VRCC response to Item 9.2 a) - please include as correspondence

Dear Mayor and Council,

In reviewing the council agenda for May 2, 2023, we saw Item 9.2 a) that we would like to address.

• The letter from the VRBA speaks to concerns regarding fast tracking the BC Energy Step Code level 4 and 5 (this relates to energy efficiency). This is not the approach that has been approved by the City of Victoria nor District of Saanich. They heard from industry a preference to not accelerate the BC Energy Step Code and instead focus on the emissions of buildings (the Zero Carbon Step Code) and as such Victoria and Saanich are aligning with the province on the energy efficiency front.
• Saanich had addressed the Radon topic back in 2018 when they first adopted the BC Energy Step Code – you can see the VRBA concerns and Saanich’s consideration of them in Attachment 4 (see page 3 for radon) of the Dec 3, 2018 Council report available here - https://saanich.ca.granicus.com/MetaViewer.php?view_id=1&clip_id=217&meta_id=11506.
  • The important thing to note here is that Saanich has not adopted energy efficiency requirements (BC Energy Step Code) higher than the base building code. They have only accelerated the Zero Carbon Step Code which supports switching from fossil fuels such as natural gas to electrification. So the radon argument that the VRBA tie to energy efficiency, would not be relevant to the recent decisions by the City of Victoria and District of Saanich.
• The reference to RNG (Renewable Natural Gas) had been covered at Saanich Council and in engagement previously and was contained within the report (Attachment 3). Their stance on RNG and how they approached it during engagement is included in Attachment 3 – the Engagement Report (see page 37). The wording is copied below:

Renewable Natural Gas & Low Carbon Fuels

• There was some discussion during the first two phases of engagement related to the ability to meet the carbon pollution standards with Renewable Natural Gas (RNG). Given this, some effort was made in the third phase of engagement to address this issue and clarify what would be considered low and zero carbon approaches in the proposed adoption pathways. As there is currently no ability for municipalities to recognize RNG for compliance with carbon pollution standards, engagement participants were asked to respond considering electrification as the only compliance path. It was noted that while FortisBC has submitted a BC Utilities Commission application that seeks to create a renewable gas and low carbon fuel rate class for new residential connections, many questions remain regarding how enforcement would be handled, what the global warming potential of these gases will be over the long term, and how permanence over the lifetime of the building will be guaranteed. FortisBC employees were active participants in the engagement and discussions.
• So in relation to the statement in the VRBA letter which reads: 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?
  • The answer to this is that Saanich is not requiring higher levels of the BC Energy Step Code but is requiring an accelerated adoption of GHG Emission Level 4 (Zero Carbon) of the Zero Carbon Step Code and RNG is not recognized as a fuel that would meet the Zero Carbon Step Code requirements.

Hope this will be helpful in addressing some of the VRBA’s statements.

Sincerely,

Cathie Blanchard, Ian Brown, Linda Jeaurond and Jane Devonshire For the View Royal Climate Coalition, VRCC