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SB-12 Updates Are Coming – Feedback Needed

DWHR Removed from SB-12 (2017) – Comments Due March 11

By Kyle Anders

Action Alert: This announcement is for builders of low-rise housing. This is a technical update, and it will impact your projects financially, so we encourage you read thoroughly and take action to have your say before the deadline next Friday.


Deadline for Comments: Friday March 11, 2016

The Ontario Ministry of Municipal Affairs and Housing (MMAH) is working to finalize the next version of the Supplementary Standard SB-12 (2017). SB-12 is the standard that Ontario home builders (i.e. for Part 9 buildings) must use to meet the minimum energy efficiency design requirements of Part 12 in the Ontario Building Code.  This SB-12 update will include more stringent energy efficiency requirements for new homes, in order to achieve the mandated target of 15% energy savings versus the current standard.  This is the first major SB-12 update since its inception in 2012, and it will come into effect for all permit applications after December 31st, 2016.  MMAH is requesting input from key stakeholders in the building, design, manufacturing and municipal government sectors to help finalize this standard, and has provided the following documents:

1) Draft MMAH SB-12 (2017) Version

2) Background Document and Comment Form

Anyone who cares about the future energy efficiency and cost effectiveness of new homes in Ontario should pay attention to this and have their voice heard on the issue.


Key Changes Proposed for 2017 Version 

  • 15% Energy Efficiency Improvement: Each SB-12 package is designed to be 15% more energy efficient than current SB-12 packages, based on an ‘average’ home.
  • Fewer Packages: To reduce redundancy of unused packages in the current version, the proposed number of prescriptive packages will be less, e.g. 6 instead of 13 for the scenario of Zone 1 – Natural Gas.
  • Now in Metric! Metric thermal values are now included in addition to imperial.  Metric continues its slow and steady march to global domination
  • Effective Thermal Resistance: Minimum thermal performance values for various assemblies are now listed in both nominal and effective.  This will give a boost to buildings that use exterior continuous insulation, well the actual performance of the entire assembly, including thermal bridging through the studs, is recognized.
  • Mandatory Heat Recovery Ventilators: Heat Recovery Ventilators is proposed to be mandatory across all packages, in order to facilitate better indoor air quality in airtight homes.
  • Credit for Reduced Air Leakage: Recognition for demonstrating increased airtightess of the building envelope with a blower door test has been added.  Improved airtightness can be used as a substitution for various insulation upgrades.
  • Drain Water Heat Recovery (DWHR) Tradeoff has Been ‘Discreetly’ Removed: While MMAH doesn’t specifically indicate this in the list of proposed changes in their Backgrounder document, the proposed SB-12 (2017) update has been scrubbed of all traces of DWHR: where builders currently have the option of being credited for including DWHR by trading off another upgrade, they will no longer have this option under the drafted SB-12 (2017) update.


No DWHR? What is Happening?

I applaud MMAH with many of the above proposed changes.  However, this last change in which they’ve removed DWHR altogether from SB-12, without even specifically mentioning this, I find to confusing at best, devious at worst, and regardless, it is counter to the public interest.  Here are a few reasons:

  • DWHR technology is a proven energy efficiency upgrade recognized in the most well known and respected home energy efficiency certification programs, including EnerGuide, ENERGY STAR for New Homes, R-2000, LEED for Homes, and HERS.
  • The energy savings of DWHR has been vetted by federal and academic research, and it is even CSA certified.  Mindscape supported the technical efforts in what would eventually become the current SB-12 tradeoffs for DWHR, demonstrating that it saves the equivalent amount of energy as the following upgrades for a typical new home:
    • R4 to above grade walls
    • R-8 to below grade (basement) walls
    • Installing an HRV
    • Upgrading window U-values from 1.6 to 1.4 W/(m2*K)
  • Manitoba recently announced they will be making DWHR mandatory for all new homes.  In other words Manitoba’s building industry felt that DWHR was such a no-brainer in reaching their next energy efficiency target level that they adopted it across the board.  The other upgrade options available to them were deemed less cost-effective, in terms of upgrade cost ($) vs. energy saved.
  • DWHR is a home-grown technology, developed and manufactured by several companies across Canada.
  • DWHR is robust and maintenance-free, unlike many of the proposed mechanical upgrade options where the equipment will have a much shorter lifespan. A case can be made that even certain envelope upgrades (e.g. windows) have a shorter lifespan than DWHR.6161213

DWHR seems like a no-brainer tool to use for new homes to achieve an additional 15% energy savings: remember, new homes are already very well insulated compared to previous code cycles, and the law of diminishing returns with insulation has designers scrambling on where to find the proverbial low-hanging fruit on the energy savings tree.  The fact that DWHR was not only excluded from other compliance options, but stealthily removed from SB-12 altogether, suggests that there is something wrong with the processes at MMAH, and that the public interest is being sidelined.

The goal of the SB-12 update to tighten up the energy efficiency standards is laudable, however the MMAH should be taking more seriously the impact this has on the cost of building new homes, and should be doing their diligence to ensure that home builders have cost-effective paths forward to achieve these laudable energy efficiency goals. Given that DWHR was not only removed from the proposed update, but not even acknowledged as one of the proposed changes, there seems to be an intentional effort to have this technology discreetly eliminated from SB-12, and this is concerning.

Needlessly Making New Homes More Expensive

In a written response to a concerned local DWHR manufacturer, an MMAH representatives gave the following rationale for not including DWHR:

Following our conversation, I’d like to advise you that we don’t intend to make changes to SB-12 to include DWHR units in the various compliance paths.  To achieve the government’s long-term climate change goals, it is critical to not compromise on the integrity of the building envelope in achieving energy efficiency“.

This is a bit of a red herring: as noted earlier, there are numerous efficiency upgrades included in the proposed SB-12 that don’t involve the building envelope, as well as some that do (i.e. windows) that have arguably lower lifespan and higher maintenance than DWHR.   Later in the response, the representative did suggest that MMAH may include DWHR for future code versions, without any clear indication of why it was removed in the upcoming version, despite being included in the current version.  MMAH seems to be buying time in what appears to be a case of internal politics and industry favoritism, rather than acting in the interest of Ontarians at large.


Protect Your Option To Use DWHR

For those of you who have had good experiences with DWHR, this is your chance to speak up and tell the MMAH that you want DWHR to continue to be included in SB-12. If you don`t speak up, then DWHR will likely not be as available to you in the future.

Please consider asking the MMAH your own version of “Why are you needlessly making new homes more expensive than they need to be in order to achieve the same result? Please put DWHR back in SB12!”  Even those of you who may not be familiar with or keen on DWHR technology, at the very least, should be upset that the MMAH is not being forthcoming about the proposed changes.  I would encourage you to think about this issue and others you find in the attached SB-12 (2017) draft, and let your voices be heard.


What You Can Do

Concerned building professionals should review the proposed SB-12 (2017) update and then complete and submit an SB-12 (2017) Comment Form by Friday March 11th with their concerns expressed.  Submit it to, with the Subject Line ‘Supplementary Standard SB-12 (2017)’.

Kyle AndersKyle Anders is a LEED® Accredited green building consultant with a background in Mechanical Engineering.  He lives in Waterloo, Ontario, and is the Manager of Sustainable Housing services for local consultant Mindscape Innovations Group (


  1. Ian Rowberry

    Thanks for the update on this Kyle. Sure doesn’t sound right that DWHR is being removed. That EcoDrain out of Montreal has struggled to get its products approved for incentives for a long time also mystifies / disappoints me. That it is not vertical, vs. the industry incumbents, seems to be the main issue, but when we’re seeking all hands to the pumps in fighting climate change, we should be looking to all tools that are proven to be cost-effective.

  2. Ted Ross

    Where does one find the evidence that supports your contention that DWHR is equivalent to R-4 etc.

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