Re: Climate Change Discussion Paper
RESCON (Residential Construction Council of Ontario) welcomes the opportunity to participate in the Climate Change Discussion and congratulates the Minister for this initiative.
Our members consist of developers and builders only. Those members represent the majority of the major companies engaged in the construction of multi-residential buildings in the Province. It is for that reason our response focuses on Section 3, Buildings & Communities of the Discussion Paper.
RESCON supports the policy direction of reducing our energy costs through the establishment of new building standards, the use of new technologies and innovations in the design and use of materials.
Our opinion, however, is that this goal cannot be achieved within the current regulatory framework that governs what we design and construct.
Radical changes are required to the entire regulatory framework that governs what we design and construct (Built-Form). The existing regulatory framework was created to address different challenges and is not receptive to, or have legislative framework to encourage the introduction of new approaches that address the challenges we face today.
Zoning, site plan control and other planning instruments discourage or prevent designs which maximize the use of economical alternative energy sources such as solar, wind and natural light. The additional capital cost of geothermal systems continues to be a disincentive for its use.
The Ontario Building Code accommodates proposals for alternative solutions to the OBC’s prescriptive approach but the requirements for obtaining approval are cumbersome, costly to implement and discourage or prevent the use of new and/or emerging technologies.
The existing structure and content of the OBC restricts, rather than encourages, the introduction of innovative approaches/solutions and the use of new and/or emerging technologies.
IDEAS and RECOMMENDATIONS
-All government functions relating to the Built-Form environment should be under one Ministry responsible for activities related to: Planning, Construction & related Infrastructure.
This would minimize overlap, improve communication and coordination, eliminate red tape as well as reducing cost.
-Replace or remove restrictive, prescriptive zoning practices which discourage and /or prevent the development of Built-Form designs which promote the adoption of alternative sources of energy.
-Provide incentives (e.g.) monetary, density bonuses, etc. to promote the use of alternative sources of energy.
-Require that all future revisions of the OBC to meet the test of a cost-benefit analysis to determine the impact on affordability & build-ability.
-Amend the OBC and aligned regulatory framework to allow and/or encourage the construction of Demonstration or Prototype projects that showcase innovative approaches to design, the use of new and emerging technologies and maximize the use of alternative sources of energy.
-Amend the OBC to include Appendix notes related to the expectations for Durability and Performance of materials & systems.
RESCON is of the opinion that:
The complex legislative environment that exists is not capable of dealing with the many factors that need to be considered and addressed, if any meaningful progress is to be made.
Any new requirements resulting from this consultation should be the subject of a cost-benefit analysis to determine their impact on affordability as it is critical in certain markets that are already clearly unaffordable.
Michael Steele, B. Tech. (C.M.)
Director, Technical Standards
RESCON (Residential Construction Council of Ontario)