BVCA submits comments on the Palliser Trail Area Structure Plan to the Town of Canmore
Re: Palliser Trail Area Structure Plan Update
Bow Valley Climate Action Society (BVCA) welcomes the opportunity to submit the following comments with respect to the Palliser Trail Area Structure Plan Update.
The Palliser Trail Area Structure Plan Update presents a unique opportunity for the Town of Canmore to demonstrate real, effective leadership consistent with its Climate Action Plan and its declaration of a climate emergency. The current draft of the ASP update needs to be substantially revised to reflect the Town’s vision for sustainability and affordability, before the ASP goes to public hearing for further community input.
BVCA is a group of Bow Valley residents who are deeply concerned about climate change. We are a volunteer organization and a registered non-profit society. We seek to promote civil citizen dialogue that spurs individual and collective action to reduce greenhouse gas emissions. One of our primary areas of focus is supporting the Towns of Canmore and Banff to fully implement their respective climate action plans.
Below is a brief summary of the key points that we wish to communicate, followed by a more detailed explanation of each of the points.
Because the Palliser Trail ASP deals entirely with public lands it presents a unique opportunity for the Town of Canmore to demonstrate its climate commitments while achieving lower total costs of building ownership / rental for those who live in and use the buildings. Such opportunity to go beyond legislated minimum building standards does not exist to the same extent where ASPs deal largely with privately owned lands.
Canmore’s Climate Action Plan recommends that the Town should “…ensure all new Town facilities including affordable housing projects are built to near net zero or a similar high green building standard…” and that the Town should…”consider mandating combined heat and power (CHP) or district energy systems in new municipal developments”.
Requiring that all construction on the Palliser lands meets very high energy efficiency standards is essential to meet the draft ASP goal of “…securing new nonmarket housing that will remain more affordable over the long-term”.
Energy-efficient buildings are more well-adapted to Canmore’s changing climate and wildlife smoke conditions.
While building on the Palliser lands may occur over several years, perhaps decades, it is expected that some building may occur in the near term, and it is therefore essential that a vision for energy efficiency be built into the ASP and/or a new Municipal Sustainable Building Policy, rather being left to future development stages.
Canada is moving rapidly towards energy efficiency standards for all new homes to be “Net Zero Ready” (NZER) by 2030, and is expected to follow with requirements for retrofitting existing buildings. Retrofits are far more expensive than building to a high standard during initial construction, so every effort must be made to ensure that all construction on the Palliser lands goes well beyond minimum standards in current building codes.
BVCA Position on Palliser Trail ASP Update
1. Because the Palliser ASP deals entirely with public lands it presents a unique opportunity for the Town of Canmore to demonstrate its climate commitments, while achieving lower total costs of building ownership / rental for those who live in and use the buildings.
The Palliser lands are owned by three public entities: the Town of Canmore; Canmore Community Housing Corporation (wholly owned by the Town of Canmore); and the Province of Alberta. It is expected that the Province will develop its parcel of land in partnership with the Town of Canmore. This provides an exciting opportunity for the Town of Canmore to establish a progressive building efficiency program through the Palliser Trail ASP Update by committing to requiring that all construction on its own lands, CCH lands, and lands developed in partnership with the Province, be undertaken to a very high energy efficiency standard.
The Town of Banff Municipal Sustainable Building Policy, which also applies to all Banff Housing Corporation construction, provides a helpful local example of a policy that has been adopted and implemented to dramatically reduce greenhouse gas emissions, energy costs, exposure to carbon pricing and total cost of building ownership for municipal buildings and affordable housing.
When considering Area Structure Plans on privately owned land the Town of Canmore is limited in its ability to require building standards that go beyond provincial building codes in effect at any given time. However, landowners, whether private or public, can voluntarily commit to higher standards, and by doing so, demonstrate leadership in climate action, ahead of province-wide adoption of higher efficiency standards.
The City of Edmonton faced a similar opportunity, on a larger scale, when it came to redeveloping the public lands formerly occupied by its municipal airport. It seized that opportunity with a vision for a sustainable, climate-friendly community (Blatchford) with a district heating system and buildings that are up to 37% more efficient than required by building codes: https://www.edmonton.ca/projects_plans/blatchford.
2. Canmore’s Climate Action Plan recommends that the Town should “…ensure all new Town facilities including affordable housing projects are built to near net zero or similar high green building standard…” (p.18) and that the Town should…”consider mandating combined heat and power (CHP) or district energy systems in new municipal developments” (p.19).
BVCA would like to see the Town of Canmore implement its Climate Action Plan and ensure that all new Town facilities and housing constructed through the Canmore Community Housing Corporation are built to near net-zero or a similar high green building standard.
BVCA also strongly encourages the Town to conduct a thorough financial and technical review of district energy and geoexchange / geothermal heating and cooling options for the Palliser Trail area, as outlined in the Town’s Climate Action Plan. The City of Edmonton ‘Building Blocks’ webinar on Geoexchange Systems provides an excellent description of the economic and GHG emission benefits of geoexchange systems (ground source heat pumps) in residential and commercial buildings in Alberta’s climate. (1)
Canmore has a unique geothermal asset in the gravel-bed river which runs throughout the Bow River valley. There are numerous examples of the successful and economic use of geothermal heating in Canmore, including in the Town’s own municipal buildings. At this stage of developing an ASP, it is an ideal moment to consider in detail how district energy could reduce GHG emissions and energy costs – prior to the construction of new buildings. As a local example of district energy in practice, The Town of Banff recently completed a district energy heating system which provides renewable energy for four municipal buildings.
Canmore’s Climate Action Plan (CAP) set an objective that 80% of all new buildings be constructed to a near net zero standard or equivalent (p.13). It recognized that “…by leading in its own Corporate operations and building management, the Town signals to the wider community that climate action is possible, necessary, and important” (p.14). The CAP contained many specific recommendations, some of which are recognized in the wording of the Palliser Trail ASP (e.g. the emphasis on walkable community, the inclusion of public transportation routes), but there are several other recommendations from the Town’s CAP that could be easily added:
encourage the development of green subdivisions;
ensure all new Town facilities including affordable housing projects are built to near net zero or similar high green building standard;
consider mandating combined heat and power (CHP) or district energy systems in new municipal developments;
support the buildout of EV infrastructure throughout the community as per the Town’s recent analysis of the role it should play in this realm; and,
install solar on all municipal buildings with adequate solar potential.
BVCA also encourages the Town to consider how Town architectural guidelines could be adjusted within the Palliser ASP area to minimize the use of dormers and other architectural features on south-facing roofs – with the objective of maximizing the potential for solar PV energy generation.
3. Requiring that all construction on the Palliser lands meets very high energy efficiency standards is essential to meet the goal, stated in the draft ASP, of “…securing new non-market housing that will remain more affordable over the long term”.
There are various recent Albertan and Canadian studies which demonstrate that there are long-term cost savings (lower total costs of building ownership) associated with building highly-efficient buildings. (2,3,4,5) These cost savings exceed the additional up-front costs at time of construction to build more energy-efficient buildings.
When the Town of Banff adopted its updated Municipal Sustainable Building Policy in 2021, it expected that there would be a 5 to 10% increase in capital costs for building construction, and that these costs would be offset over the life of the building by energy cost savings, with an estimated payback of 20 to 30 years (6). The increased capital cost for constructing the recent Roam Transit Garage to a net-zero LEED-certified standard was 4%. The Town of Banff states that one of the objectives in implementing its Municipal Sustainable Building Policy is to “yield long-term cost savings to rate payers and building occupants through reduced life cycle energy, maintenance, and retrofit costs for all buildings under municipal control” (7).
BVCA would like to see the Palliser Trail ASP and/or a new Town of Canmore Municipal Sustainable Building Policy ensure that construction on the Palliser lands results in the same cost savings and long-term affordability for Canmore rate payers and residents.
Canmore will always be an attractive place to live, resulting in continued demand for housing and upward pressure on land values. Providing affordable housing for renters and owners will be a difficult long-term challenge. In an environment characterized by increasing energy prices, increasing carbon pricing and a changing climate, the focus cannot just be on achieving the lowest possible initial building costs. Ongoing energy costs must be reduced through high levels of insulation, high quality windows and doors, building forms that minimize heat loss, and building orientations that capture passive solar potential.
An equally important consideration with respect to Canmore’s objective of developing housing that is affordable in the long term, is the fact that, in order to meet its climate goals Canada at some point will need to enact stringent regulations with respect to retrofitting existing homes. This could result in very high future renovation costs for buildings that have not been built to high standards for building envelopes, windows and doors, and wired to accommodate increased electrification.
4. Energy-efficient buildings have better air quality and are better adapted to Canmore’s changing climate and wildlife smoke conditions.
Energy efficient buildings which have high levels of insulation, high-quality windows and doors and mechanical ventilation also attenuate noise and provide higher indoor air quality. These are both especially important given that buildings constructed in the Palliser Trail area will be close to the TransCanada Highway. Energy-efficient buildings also remain cooler during extreme heat events and maintain higher indoor air quality during wildfire smoke events – both important adaptations to the changing climate in the Bow Valley.
5. It is essential that a vision for energy efficiency be built into the Palliser ASP, rather than being left to a later development stage.
The Palliser ASP Update does not provide any indication of the likely phasing of development. It seems reasonable to assume however, that the various parcels will be developed over many years. As the world is changing rapidly with respect to building technology and standards, there may need to be updates of energy efficiency requirements. However, given Canmore’s stated commitment to climate action it is critical that a very clear vision and specific guidance be given from the outset.
CCH has indicated that they intend to act very quickly on at least one of their parcels as soon as the ASP is finalized (8). They could be issuing Requests for Proposals before the end of 2023. Clearly, the ASP should not be finalized until it contains strong guidance on the energy efficiency of buildings, and/or the Town of Canmore has adopted a Municipal Sustainable Building Policy (that includes CCH) which addresses these needs – prior to construction on the Palliser Trail ASP lands.
6. Canada is moving rapidly towards energy efficiency standards for all new homes to be “Net Zero Ready” by 2030, through five phased “steps”, beginning immediately, and is expected to follow up with requirements for retrofitting of existing buildings.
In March 2022, the Canadian government released the National Energy Code for Buildings (NECB 2020) and the National Building Code (NBC 2020). These are ‘model’ building codes: provinces have jurisdiction over building codes and it is expected that all provinces will adopt the model codes although they are likely to set different timelines for achieving the five efficiency ‘tiers’.
Within a few years the Government of Canada is likely to introduce new standards for retrofitting existing buildings to meet higher energy efficiency standards. Given that energy retrofits are far more expensive than building to a high standard from the outset, it is critically important that provinces adopt a rapid path through the five efficiency tiers, and that municipalities lead the way by adopting a rapid path where it is within their jurisdictions to do so.
In conclusion, Bow Valley Climate Action Society fully recognizes and supports the stated objective of using the Palliser lands to “…focus on securing new non-market housing that will remain more affordable over the long-term”. Long term affordability requires building to standards today that will result in energy savings in the near term and reduce the need for expensive energy retrofits in the future.
BVCA also recognizes that high standards for energy efficiency must be built into the updated ASP and/or outlined in a new Municipal Sustainable Building Policy rather than developed at a later date, as Canmore Community Housing Corporation intends to proceed to Requests for Proposals on one of the properties very soon after the ASP amendment is issued.
Thank you for the opportunity to provide our input on this important project, and we welcome the opportunity for further discussion of these ideas.
Sincerely, the Bow Valley Climate Action Society
1 Komar, J. Geoexchange Systems. City of Edmonton Building Blocks webinar series.)
2 Nostedt, J. 2022. Total cost of building ownership: Can high-performance buildings actually save you money? City of Edmonton Building Blocks series.
3 Integral Group. 2020. City of Edmonton Emissions Neutral Buildings: Final Report.
4 Daily Commercial News-Construct Connect. 2021. Climate and construction: the dollars and sense behind total cost of building ownership.
5 Zebx. 2021. Construction cost analysis of high-performance multi-unit residential buildings in British Columbia.
6 Hay, M. 2021. Town of Banff Request for Decision – Proposed New Municipal Sustainable Building Policy. Presented to Town of Banff Council April 26, 2021.
7 Town of Banff. 2021. Municipal Sustainable Building Policy. https://banff.ca/DocumentCenter/View/344/Municipal-Sustainable-Building-Policy-C7006
8 https://www.canmorehousing.ca/wp-content/uploads/2023/03/CCH-Board-Meeting-Public-AgendaMarch-30-2023.pdf. See attachment re: amended business plan.