+ RMA Rural Municipalities
of Alberta

Resolution 3-23S

Amendments to the National Building Code

February 23, 2023
Expiry Date:
March 1, 2026
Active Status:
Mackenzie County
4 - Northern
Planning and Development
Accepted in Part
Vote Results:

WHEREAS Alberta Municipal Affairs administers the Safety Codes Act, which establishes a legislative framework for the development of safety codes and the delivery of safety code services for municipalities, industry and the public in Alberta; and

WHEREAS Alberta Municipal Affairs is supported by the Safety Codes Council, which makes recommendations on public safety to the Minister of Municipal Affairs and accredits municipalities, corporations and agencies to deliver inspection, permitting and enforcement services as well as train and certify safety code officers; and

WHEREAS in Canada, provincial and territorial governments have the authority to enact legislation that regulates building design and construction within their jurisdictions; and

WHEREAS this legislation may include the adoption of the National Building Code (NBC) without change or with modifications to suit local needs, and the enactment of other laws and regulations regarding building design and construction, including the requirements for professional involvement; and

WHEREAS the NBC is a model code that helps promote consistency among provincial and territorial building codes; and

WHEREAS the Canadian Commission on Building and Fire Codes (CCBFC) is responsible for the content of the National Model Codes; and

WHEREAS Codes Canada (formerly named the Canadian Codes Centre) of the National Research Council (NRC) provides technical and administrative support to the CCBFC and its standing committees; and

WHEREAS the NRC publishes periodic revisions to the National Model Codes to address pressing issues; and

WHEREAS the Government of Canada has committed to developing a net-zero emissions model building code for provincial/territorial adoption; and

WHEREAS the Canadian Board for Harmonized Construction Codes has agreed that the National Model Codes include an objective for greenhouse gas (GHG) emissions reduction to enable provincial and territorial regulation, and this objective should be incorporated into the 2025 codes; and

WHEREAS this objective will affect Albertans’ use of fossil fuels to heat homes, appliances, and the use of cogeneration that is needed for electricity, with the goal of eliminating all GHG emissions on site; and

WHEREAS this objective will affect Alberta’s use of purchased electricity such as electric equipment, and equipment that uses purchased energy, district heating and cooling, with the goal of eliminating GHG emissions off site; and

WHEREAS the implementation of a net-zero emissions model will lead to a significant escalation in costs for new buildings and challenges to home affordability;

Operative Clause:

THEREFORE, BE IT RESOLVED that the Rural Municipalities of Alberta (RMA) advocate to the Government of Alberta to ensure that the proposed changes to incorporate greenhouse gas emissions reduction into the National Building Code  consider the negative effects to all Albertans, specifically rural Albertans and their quality of life; and

FURTHER BE IT RESOLVED that the RMA advocate to the Government of Alberta and the Safety Codes Council to participate in the consultation process related to updating the National Model Codes to ensure that the needs of Albertans are at the forefront; and

FURTHER BE IT RESOLVED that RMA advocate to the Government of Alberta to not incorporate net-zero emissions code requirements into the 2025 National Building Code – Alberta Edition (NBC(AE)).

Member Background:

The Canadian Board for Harmonized Construction Codes (CBHCC) has agreed that the National Model Codes include an objective for greenhouse gas (GHG) emissions to enable provincial and territorial regulation, and this objective should be incorporated into the 2025 codes.

In the initial stages of developing this policy framework, provinces and territories (PTs) noted a number of elements for consideration, including:

  • principles and factors that all PTs agree on (e.g., ultimate goal and net zero emission definition, emission factors);
  • the need to accommodate the breadth of PT fuel policies, plans and individual PT targets, and coordinate with elements that extend beyond the boundary of the code;
  • regional differences (e.g., ability to fuel switch, availability of low embodied carbon materials in Northern and remote areas);
  • the boundary of operational emissions (e.g., address scope 1 only? Or address both scope 1 and scope 2 emissions?) and embodied emissions (i.e., determine standard method of analysis);
  • impact on affordability (e.g., interplay between energy efficiency and GHG requirements with respect to operational GHG emissions);
  • development and availability of data (e.g., better granularity of emission factors for operational carbon, better availability of Environmental Product Declarations for embodied carbon, standard method of analysis for embodied carbon);
  • implementation approach (e.g., phased approach, flexible approach to address specific needs of PTs);
  • adoption and implementation considerations including market readiness, training, capacity building (monitoring, reviewing and enforcement), and developing tools to enable PTs to harmonize.

Prior to the transition to the new Harmonized Code Development System, the Canadian Commission on Building and Fire Codes (CCBFC) agreed to ask the standing committees to start working on developing technical requirements that would address GHG emissions in parallel to the ongoing policy work to:

  • address the eight policy elements identified by PTs, and
  • develop language for a new GHG objective.

In November 2022, the CBHCC adopted the direction set by Canadian Commission on Building and Fire Codes, including:

  • developing objective(s) to address GHG emissions for inclusion in the 2025 National Model Codes;
  • developing proposed technical requirements related to operational GHG emissions for inclusion in the 2025 National Model Codes;
  • developing proposed technical requirements related to embodied GHG emissions for inclusion in the 2030 National Model Codes; and
  • undertaking policy work, and objective and technical development in parallel.

The CBHCC is seeking input from stakeholders, experts, code users, and the general public on the draft policy recommendations before finalizing the policy framework. The draft policy recommendations will also be provided to the relevant standing committee(s) for discussion.

  • Consultation wave 1 begins on February 6, 2023 and ends on March 30, 2023.
  • Consultation wave 2 is planned to begin in March 2023 and end in May 2023.

Note that this consultation period is subject to change as the CBHCC is still working on the draft policy recommendation.

RMA Background:

RMA has no active resolutions directly related to this issue.

Government Response:

Alberta Municipal Affairs

The Government of Alberta recognizes the importance of affordability, while also supporting energy efficient building construction in Alberta. The province is updating its construction codes based on the 2020 NBC, National Fire Code, and National Energy Code for Buildings, which were published by the National Research Council in March 2022. Municipal Affairs, in collaboration with the Safety Codes Council and relevant groups, reviews the new codes to ensure alignment with provincial policy and Alberta’s needs, as well as interprovincial trade objectives and to support labour mobility.

Groups that provide input to each new addition of the safety codes include:

  • the RMA;
  • Alberta Municipalities;
  • representatives from both rural and urban municipalities;
  • the Building Industry and Land Development Association Alberta;
  • Association of Professional Engineers and Geoscientists of Alberta;
  • Building Owners and Managers Association;
  • technical experts across Alberta, including experts in energy efficiency; and
  • Safety Codes Officers.

All provinces and territories have signed the Construction Codes Reconciliation Agreement, which commits to reducing or eliminating provincial variations in construction codes. Alberta and other provinces and territories have constitutional authority for codes and standards and there is recognition that jurisdictions may have circumstances in which there is a policy imperative to vary from the national codes. Alberta, along with all other provinces, retains the authority to make variations to national codes based on provincial policy priorities or interests, such as public security and safety, protection of the environment, consumer protection, and other policy priorities.

Alberta recently exercised this authority in the decision to adopt Tier 1 as the minimum provincewide standard for building energy efficiency for housing and small buildings under Part 9 of the Alberta edition of the NBC as well as Tier 1 for energy efficiency for other buildings in the National Energy Code for Buildings. The five new energy efficiency tiers in the national codes provide incremental progression toward net-zero energy efficiency. The predetermined tiers are designed to provide a flexible framework and choice on the performance level and cost most appropriate for provinces and territories to increase energy efficiency. For energy efficiency tiers, stakeholders communicated a strong consensus that Tier 1 was the preferred approach for Alberta.

The next Alberta edition of the building, fire, and energy efficiency codes will come into force in spring 2024. Municipal Affairs recognizes that municipalities require flexibility to appropriately manage the transition period for the administration of new code requirements. Municipal Affairs will provide additional notifications and information on the exact date, along with other information related to the updated codes over the coming months, to ensure municipalities and code users are prepared in advance of the coming into force date. The new Alberta editions of the national building and fire codes will be published in fall 2023.

Municipal Affairs also recognizes that the RMA is an important voice in the code review with other municipal, industry, safety, and agricultural sector representatives to ensure that updates to Alberta’s editions of the national building, fire, and energy codes enhance public safety, while supporting housing affordability and fostering economic growth.

Alberta is a member, along with other provinces and territories, of the Canadian Board for Harmonized Construction Codes that makes recommendations to the Provincial/TerritoriaI/ Federal Deputy Minister Table for Canadian Codes on the policy direction of the national codes. As a member of the codes board, Alberta is consulted on all proposals and developments for the national codes and works and consults with the Safety Codes Council and municipal, industry, and other representatives on all code development.


The Government of Alberta response indicates the province’s efforts to support a consistent nationwide approach to building codes with a willingness to diverge from national consensus to adopt requirements that meet the needs of Albertans. While this is appreciated, the resolution request Alberta not to adopt net-zero emissions code requirements into building codes, whereas Alberta has adopted Tier 1 requirements.

Because the Government of Alberta has participated in national building code engagements (as requesting in the second operative clause of the resolution), this resolution is assigned a status of Accepted in Part, and RMA will continue to advocate for more flexibility in building codes related to net zero requirements.

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