Written in collaboration by Holly Jordan, Chair of the Greater Toronto Chapter’s Advocacy Committee and Senior Associate, B+H Architects; and Sundeep Virdi, Manager, Advocacy & Policy, Canada Green Building Council (CaGBC).
This article was originally published in the CaGBC’s Toronto Focus supplement for Spring 2016. Toronto FOCUS is a joint publishing project of the Greater Toronto Chapter of the CaGBC and SABMag.
By fall of 2015, the Province put forward amendments (Bill 135 Energy Statute Law Amendment Act, 2016) to the Green Energy Act, 2009 that would enable the MOE’s proposed large building energy and water reporting and benchmarking initiative. These amendments would require large building owners to publicly report energy and water usage, and building information. Additionally, utility companies would be required to release data related to energy and water use to building owners. In early 2016, further details to these requirements were provided in a final draft form of Bill 135. Ontario’s largest buildings potentially would be required to report for the first time in winter 2017, with smaller properties to be included incrementally in the following years.
Since many Canadian municipalities are considering energy benchmarking like Toronto, an overarching framework that advocates for effective program design principles underpinning regulations would be highly valuable. A cohesive approach would reduce EWRB implementation challenges for policy makers and property owners that own and operate buildings across multiple jurisdictions. Additionally, a national framework would support the large range of capacities Canadian cities have to develop and deliver complex environmental policies.
Working in parallel with the Toronto and Ontario movement, the Canada Green Building Council (CaGBC) convened a Working Group of experts in September 2015 to discuss the principles for a National Framework for Energy Benchmarking, Reporting and Disclosure founded on the idea that a standardized approach to EWRB will support governments and industry members interested in reducing energy use and GHG emissions. The working group established a shared understanding on the importance of a national EWRB approach and from that understanding, agreed on key principles including consistency, effectiveness, transparency, and capacity building, to facilitate the development of EWRB policies. Finally, the group identified key government recommendations drawn from their discussions.
Highlights from the white paper include:
- Roles and responsibilities for key actors in supporting EWRB regulations, including provincial bodies, local governments, federal bodies, utilities, industry associations and non-governmental organizations, and academic and research institutions.
- Identification of key synergies between local, provincial, and federal levels to distribute responsibilities and burdens, make use of existing capacities, and ensure coordination and consistency across jurisdictions for the development of EWRB programs and regulations.
- Partnering opportunities with non-governmental stakeholders to leverage existing EWRB expertise and experience to increase awareness, build capacity, and facilitate compliance with new regulations. The white paper will be shared with provinces and local governments interested in pursuing EWRB regulations to guide consistency across Canada.
The outcomes of the Working Group discussions were released in a summary report titled National Energy Benchmarking Framework: Report Preliminary Working Group Findings. This framework laid the groundwork to engage key stakeholders for further consultation and the development of a white paper, detailing specific factors for effective EWRB implementation.
Up to 40 municipal and industry stakeholders across Canada and up to 10 jurisdictions from the United States were brought together from December 2015 to February 2016. Additionally, a joint session was hosted by CaGBC, Toronto Atmospheric Fund, and Integral Group at the Federation of Canadian Municipalities’ Sustainable Communities Conference held in Ottawa on February 10, 2016; attended by over 70 Canadian stakeholders representing 30 municipalities and over 20 industries. The draft white paper was prepared in March 2016, and identified recommendations for feedback for five major areas including: Program Administration, Program Delivery, Data Quality Control, Data Transparency, and Building Industry Capacity.
The final outcome is a white paper titled Energy Benchmarking, Reporting & Disclosure in Canada: a Guide to a Common Framework; released in early April, 2016; which sets parameters for a consistent approach to energy benchmarking on a national scale. The White Paper was subsequently sent along with a formal response submission from CaGBC National and the Greater Toronto and Ottawa Chapters to the Ontario MOE on the proposed Large Building Energy and Water Reporting and Benchmarking regulation.
As an organization, CaGBC is pleased at the EWRB progress that has taken place over the last year, extending thanks to its key partners, the Real Estate Foundation of BC (REFBC), Toronto Atmospheric Fund (TAF), Integral Group and Working Group members, while recognizing the contributions by REALpac and many others to make this happen. The participation of local, provincial, and national entities has offered collective strength in this growing development. Stay tuned as this key advocacy initiative evolves into its official form in Ontario, ideally laying the groundwork for other provinces and/or jurisdictions to follow.