Alberta Building Code changes threaten hydronic industry


The hydronic heating industry is fighting new environmental regulations that will triple the amount of insulation required under hydronic floor heating slabs in some parts of the country.

“If it gets put in place as it is it is going to kill the radiant floor heating industry,” remarked Barry Cunningham, general manager at Triangle Supply in Red Deer, Alberta. A residential project that might have cost $8000 last year will now cost $16,000. “In my opinion, it’s going to take it beyond the resources of the homeowner.”

Alberta adopted Section 9.36 of the National Energy Code for Buildings into the Alberta Energy Code in May, with enforcement beginning Nov. 1. This new code requires a minimum R-value for underslab insulation of R-16, which equates to 3-1/2 to four inches, plus additional insulation around the perimeter of the slab. Current practice is one inch of foam insulation or about R5 as required by the CSA B214-12 Installation Code for Hydronic Heating Systems.

The National Energy Code divides the country into geographic regions depending on climate – these requirements are for Zone 7, which includes much of Alberta.

The Canadian Hydronics Council (CHC) estimates that the change could add as much as 300 percent to the cost of a radiant floor heating system.

In addition to more insulation, the change will require thicker slabs and more rebar to prevent deflection of the slab. The excavation will have to go deeper. “If it is not skating rink flat, the potential for voids underneath becomes larger,” noted Cunningham. Depending on the design of the walls and footings, they may have to go deeper as well.

Competitive disadvantage

The irony, noted CHC program manager Matt Wiesenfeld, is that these changes could push building owners to less efficient technologies. Forced air heating, for example, requires no underslab insulation.

“It’s really not fair,” added Cunningham, noting that any building with any form of heating can benefit from insulation. And he wonders how federal code officials came up with their numbers. “We have a pretty good amount of data that shows they are just plain wrong.”

The Canadian Hydronics Council and the Canadian Institute of Plumbing & Heating is urging the Alberta government to engage in meaningful industry consultation including:

  • A review of the building science of the insulation requirements to confirm they will have the desired impact
  • Examination of the additional data showing how hydronic heating can be a reliable energy efficient option.
  • Implementation of strategies that give homebuilders and owners the freedom to choose the right solutions based on their needs.

The CHC is awaiting a formal response from the Alberta government.

However, some jurisdictions, including Calgary, have already informed the industry that building permits issued for projects beginning Nov. 1 must meet the new requirements.

Still busy, but …

Cunningham noted that the industry is still busy with projects for which permits were obtained earlier, but that work will quickly dry up if the Alberta government does not amend the new underslab insulation requirements.

There is an alternate compliance path in which an engineer can recommend a different level of insulation after doing heat transfer soil tests.
“That’s not going to happen,” noted Cunningham, adding that the majority of the residential and agricultural radiant floor heating projects do not involve engineers.

And, he notes, this could quickly spread across the country because it is part of the 2015 National Building Code. B.C. has also implemented it.

Building codes have traditionally been designed to ensure that buildings are safe. Environmental issues have brought politics into it. “This is a political solution; it’s not a safety codes issue,” remarked Cunningham.


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