Sign Now To Support Embodied Emissions Being Addressed In Building Code



Nickel Bros

Cassidy v. Ros



March 19, 2024


Sign Now To Support Embodied Emissions Being Addressed In Building Code

[BC, Canada, March 19, 2024]Jeremy Nickel of Nickel Bros is seeking support for the immediate release of a Provincial bulletin that will clarify existing Code mandates for relocated homes.

Currently, Code mandates for relocated homes are contained in supporting documents rather than in the body of the Code. These state that as existing homes, they do not require upgrades to new building standards. However, the inaccessibility of this documentation results in confusion as to the treatment of relocated homes in BC municipalities and regional districts, which in turn creates building permitting delays and the output of additional resources by these organizations, home owners, and contractors.

This clarifying bulletin has been in process for 4 years, and was “approved for distribution” by Ministry staff on November 3, 2024. The release date has been continually pushed back due to Provincial and Federal mandates that prioritize new builds and operational carbon, meanwhile the increased FSR allowances are projected to increase demolition rates even further.

Metro Vancouver, as an example, approved roughly 3000 demolitions per year prior to the FSR changes. These 3000 demolitions equal 210,000 tonnes of embodied carbon being released into our atmosphere, and 195,000 tonnes of waste added to our landfills. Each of these new-built homes has an approximate carbon payback period of 186 years, as per UBC’s teardown index. To exacerbate this further, we are now seeing homes being slated for demolition that are less than 10 years of age - Nowhere close to reaching their carbon payback period to be able to offer meaningful carbon savings, regardless of operational emissions Code mandates.

It is projected that approximately 40% or more of Metro Vancouver homes would be good candidates for relocation to Coastal and Indigenous communities, where building costs often exceed $500 per sq.ft. By contrast, a relocated home can be delivered and installed to these communities for only $120 per sq.ft. on average.

If the Province will fulfill their role of providing guidance to local governments, and clarify the Code applications for relocated homes across all of BC, we have the opportunity to generate impactful carbon savings for ourselves, our neighbors, and future generations, as well as clear up some of the backlog in building permitting departments.

This bulletin also reflects the ask being made via Code Change Request 2102 at the Federal level, which would expand this clarification across all of Canada. The Federal government has said they will not consider embodied carbon in Building Code until 2030; by that time it will be far too late to correct the damage that is being done. We will have lost 10s of 1000s of well-built homes from Canada’s housing stock, while our homeless population continues to increase due to affordability concerns. Relocated homes are a way for the Provincial and Federal governments to address affordability and climate action in one - And they are refusing to do so due to the siloed nature of these priorities.

Read supporting docs: here, lend your support by signing the letter: here, and send it to for circulation to Provincial and Federal decision makers. If you are authorized to represent an organization, please place the letter on your letterhead.

Need a different file format? Email Cassidy v. Ros at with a file type request and she’ll get it to you ASAP!

The Provincial and Federal governments need to recognize that embodied carbon plays a large role in climate change and that existing housing stock is affordable housing stock, and they need to hear this from us now, before it’s too late!

(Note: This bulletin is additionally supported by the BC Structural Movers’ Association and the International Association of Structural Movers.)

Additional resources:

UBC Teardown Index:

Housing conditions among First Nations people, Métis and Inuit in Canada

Tired of waiting for a federal strategy, off-reserve Indigenous housing providers in BC create their own.

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