Manitoba Eco-Network Comments on the Proposed Adoption of the 2025 National Model Codes
On October 23, 2026 the Man
itoba Eco-Network submitted comments on the proposed regulatory changes that will result in Manitoba adopting the 2025 National Model Building Codes. Our comments were submitted via the Manitoba Regulatory Accountability Portal, and can be read below.
Through regulatory changes under The Manitoba Buildings Act, Manitoba is proposing to finally replace the 2020 National Energy Code of Canada for Buildings (2020 Code) with the 2025 National Energy Code of Canada for Buildings (2025 Code) on June 23, 2027. The National Building Codes (building codes) will move from Tier 1 to Tier 3 (Tier 5 being the top tier) and National Energy Building Codes (energy codes) will move from Tier 1 to Tier 2 (Tier 4 being the highest tier), both on June 1, 2028.
The Manitoba Eco-Network (MbEN) appreciates the opportunity to comment on the Proposed Adoption of the 2025 National Model Codes.
MbEN is a non-profit registered charity which seeks to strengthen Manitoba’s environmental community with the goal of protecting our environment for the benefit of current and future generations. MbEN facilitates connections, engages in advocacy opportunities, and undertakes community-based research that promotes meaningful public participation in environmental governance processes.
Some of the work we do engages with the questions pertaining to the built environment:
- Through our partnership in research on financing deep energy retrofits, we have seen how costly it is to fix buildings after the fact: full upgrades of existing buildings often run $100,000 to $200,000. Getting it right at construction costs a fraction of that.
- As intervenors in the Public Utilities Board’s review of Manitoba Hydro’s 2025 Integrated Resource Plan, we saw how closely building performance and the province’s energy future are tied together. Hydro needs about 1,760 MW of new capacity by 2035, driven by winter peak demand, and is counting on energy efficiency and other customer-side measures to meet nearly half of it. Getting there will require government investment and regulatory changes. Every new building built to a higher standard lowers that winter peak for its entire life. That is generation Manitoban ratepayers do not have to pay for. This could defer the need to waste $3 billion or more on new gas-fired turbines that will drive electricity rates up and increase GHG emissions.
- Through our Home Energy Use Map project, we have seen how much Manitobans want to show the work they have put into their homes, and to see what others have done. This is an argument for moving towards energy labelling for buildings. Another step which the province has committed to but not yet taken.
- Throiugh our Climate Safe, Green City project we have conducted an energy poverty survey, which confirmed that residents do struggle to afford energy costs and to maintain comfort in their homes, and we have also encouraged the use of natural methods to reduce heating and cooling costs, such as tree planting and using vines to create shade.
MbEN welcomes the province’s proposal to adopt the 2025 Code and raise energy efficiency requirements for new buildings by adopting higher tiers. However, we feel that the proposal does not go fast or far enough; nor does it provide a plan for what comes after 2028, or how or when we will adopt the 2030 code when it is released.
MbEN recommends that the Government of Manitoba:
- Adopt Tier 3 under the National Building Code (section 9.36, homes and small buildings) and Tier 2 under the National Energy Code for Buildings (larger buildings) on June 22, 2027.
- A plan for the adoption of Tier 4 building codes and Tier 3 energy codes should be in place by January 1, 2028, with a targeted adoption date of January 1, 2029. These plans should include engagement with both industry and the general public (who in the past have generally been excluded from these discussions).
- Add electric vehicle ready requirements to the final regulation as committed to in the Affordable Energy Plan.
- Set out a plan to meet or exceed the highest tiers possible before 2030, which needs to include a plan to be prepared to adopt the 2030 code at the highest tier level as soon as possible with a target of less than the 18 months required for adoption under trade agreements. Once again this needs to be done with both industry and the general public.
- Revise the Green Building Policy for government-funded construction, to ensure housing, schools, care homes, clinics, and other new construction funded by government meet the higher tiers now, and begin work on embodied carbon measures for future code cycles.
- Invest significantly in training and compliance capacity: for builders, trades, energy advisors and building officials, with particular attention to rural and northern communities, so there are enough trained people to build to higher tiers and to verify that buildings meet them.
Buildings account for 13% of Manitoba’s greenhouse gas emissions, mostly from heating. Updating the codes to ensure every new building is as efficient as possible is one of the easiest things this government can do to reduce emissions. Adopting higher codes leads to few direct costs for the government beyond training and compliance. It may increase the costs of a new building, but the added carrying costs are often less than the savings on energy bills. For instance the Proposed Regulation Information document provided as part of this engagement states:
“An industry market assessment found that moving from Tier 1 to Tier 3 of the NBC for housing would add approximately $4,850 dollars to a modelled home, with those added construction costs recovered through utility savings within 8.4 years. The initial cost increases would be recovered multiple times over the life span of a home (approximately 100 years). The industry market assessment also noted that construction cost increases may be lower than $4,850 because many homes in Manitoba are likely already being built to a higher performance standard.”
When something makes that much economic sense we should not delay.
Many in industry are ready for the change, there will always be some in industry that will make excuses and be resistant to change, but nudging industry to move faster through regulatory changes like this is better for the economy. It reduces energy use, lowers GHG emissions, enhances affordability, creates jobs, trains the workforce, and increases the value of our building stock.
Adopting higher energy and building codes was a key campaign promise of this government in 2023. It also featured prominently in Manitoba’s Affordable Energy Plan released in September 2024. And it was featured again in Manitoba’s Path to Net Zero released in October 2025.
We encourage the government to move forward with the adoption of building and energy tiers on a more expedient basis. There is no need to further delay action. Every new building built at a lower tier level locks in higher emissions, energy use, and operating costs for the next 100 years or more.
Building codes are also about the people who live and work inside. Efficient buildings are warmer in winter, cooler in summer, healthier to live in, and cheaper to operate. Every building built right today is one that will never need public retrofit dollars later. And warmer, drier homes with filtered ventilation mean fewer illnesses linked to cold, damp housing and wildfire smoke, easing pressure on the health system the province pays for. It is in the best interest of all Manitobans to live in a resilient province, and this is a key way to make that happen.
Moving to higher tier building and energy codes is one step in the right direction. But it is not the only action needed. Updating Manitoba’s laws and regulations to: enable Property Assessed Clean Energy (PACE) financing, introduce home energy labelling, enable energy as a service model to operate, create structures for green financial institutions that are focussed on lending to finance deep energy retrofits for buildings and other actions that reduce GHG emissions are other needed actions. Perhaps most importantly we need major government investments in retrofitting older building stock in the province. Increasing the energy efficiency of new buildings through higher tiers in the building and energy codes has a good payback return and therefore will likely be financed by the private market, but updates to older housing stock is likely to require major government investment. Although enhanced codes are part of the solution, if we only address new builds through code updates without concomitant investments in retrofitting older building stock we are likely to create inequitable societal outcomes, so it is incumbent that we do both at the same time.
We thank the government for reviewing our comments and ask that our recommendations outlined above be implemented without delay. Please do not hesitate to reach out should you have any questions, comments or concerns.
Sincerely,
James Beddome
Executive Director, Manitoba Eco-Network
executivedirector@mbeconetwork.org
SOURCES:
[1] Province of Manitoba, Proposed Regulation Information, 2025 National Model Codes (September 2026). https://engagemb.ca/2025-national-model-codes
[2] National Building Code of Canada: 2025 https://nrc-publications.canada.ca/eng/view/ft/?id=adf1ad94-7ea8-4b08-a19f-653ebb7f45f6
[3] National Energy Code of Canada for Buildings: 2025 https://nrc-publications.canada.ca/eng/view/ft/?id=0d558a8e-28fe-4b5d-bb73-35b5a3703e8b
[4] Manitoba Hydro, 2025 Integrated Resource Plan (IRP) and Major New Facilities (MNF) filing review by the Manitoba Public Utilities Board.
https://www.pubmanitoba.ca/v1/proceedings-decisions/appl-current/2026integratedresourceplan.html
[5] Manitoba Hydro, General Rate Application for 2026-2028 (March 28, 2025) review by Manitoba Public Utilities Board. https://www.pubmanitoba.ca/v1/proceedings-decisions/appl-current/2026-2028-mh-gra.html
[6] IISD, Manitoba Builds Green (2024). https://iisd.org/publications/report/manitoba-builds-green
[7] Canadian Home Builders’ Association, Understanding Tiered Energy Efficiency Requirements (2025 National Building Code). https://hub.chba.ca/member-knowledge-centre/Details/understanding-tiered-energy-efficiency-requirements-backgrounder-302471
[8] National Research Council of Canada, National Energy Code of Canada for Buildings, Part 10: Tiered Performance. https://nrc.canada.ca/en/certifications-evaluations-standards/codes-canada/codes-canada-publications
[9] Province of Manitoba, Manitoba’s Path to Net Zero, Actions 8.1 and 8.5. https://www.gov.mb.ca/asset_library/en/netzero/mb-path-to-net-zero.pdf
[10] Province of Manitoba, Affordable Energy Plan, Action 6.3. https://www.gov.mb.ca/asset_library/en/energyplan/mb-affordable-energy-plan.pdf
[11] Electric Autonomy Canada (September 28, 2026). https://electricautonomy.ca/charging/multi-unit-buildings/2026-09-28/municipalities-murb-requirements/
[12] Province of Manitoba, Path to Net Zero: Three-Year Action Plan, Actions 1-H, 8-C and 8-D. https://www.gov.mb.ca/asset_library/en/netzero/path-to-net-zero-three-year-action-plan.pdf
