The City of Toronto will soon begin to consult building owners and managers on the development of a bylaw that, if approved, will establish an energy reporting requirement for large buildings.
An interim report recently set out a fall to winter timeframe for soliciting stakeholder input, which the city will do in cooperation with a professional firm to be hired in September or October. Staff expect to present a proposed bylaw and implementation plan to City Council in the second quarter of 2015.
The report, considered at the parks and environment committee’s Aug. 15 meeting, also provides insight into some of the different reporting and disclosure options city staff is investigating.
Address; year built; gross floor area; natural gas, electricity and water consumption; greenhouse gas (GHG) emissions; and an efficiency benchmark rating or score are all identified as possible parameters for reporting, which would occur annually. Reporting would exclude personal, financial or proprietary information.
The report discusses three possible approaches to disclosure. Building data and benchmarking results could be shared amongst subject building owners only, with the broader public or, on a transactional basis, with prospective buyers at the time of sale.
The combination of tracking and comparing energy and water use and public disclosure appear to be key to improved building performance in cities such as New York and Chicago where comparable programs already exist. The report cites a U.S. Environmental Protection Agency finding that buildings participating in the Energy Star Portfolio Manager’s benchmarking program saw a seven-per-cent increase in energy-consumption savings between 2008 and 2011.
The Canadian version of Energy Star Portfolio Manager, a free online tool, has been identified as a potential candidate for use in the City of Toronto’s proposed program. The only catch is that the benchmarking tool has yet to apply its one-to-100 scoring system to multi-residential buildings.
The report doesn’t establish which building types and sizes might be subject to the proposed bylaw, other than to say that energy reporting bylaws are typically applied to multi-storey commercial, public and residential buildings. (In Ontario, public buildings are already subject to energy reporting requirements through the Green Energy Act.)
In the U.S., benchmarking requirements are generally applied to commercial and, in some cases, multi-residential, buildings measuring 50,000 square feet or more.
Coun. Mary-Margaret McMahon says she will defer to city staff on which building sizes should be subject to the proposed energy reporting bylaw. McMahon sits on the city’s parks and environment committee and was one of five signatories to the letter that triggered the initiative.
“People don’t realize that such a large percentage of GHGs come from our building sector,” she says.
Indeed, according to the report, about half of the city’s GHGs comes from building operations, including lighting and space heating.
An energy reporting requirement would help building owners understand how their building is performing, McMahon says. And what she views as an opportunity to reduce GHG emissions can also be viewed as an opportunity for building owners to reduce their energy costs by taking steps to improve their building’s efficiency and potentially accessing grants for that purpose.
But for the bylaw to be effective, the city councillor believes disclosure needs to be public.
“It benefits prospective buyers, it benefits current owners … it might get tenants or users of the buildings challenging each other,” she says. “It’s not to shame each other; it’s just to encourage each other, and empower each other, to do better, to do more. And the benefit of that is the money that you save.”
As far as Coun. McMahon is concerned, Toronto is behind on energy reporting, so she thinks the city should “jump in with both feet and get going.”
But Michael Brooks, CEO of the Real Property Association of Canada (REALpac), cautions against rolling out the program too quickly.
“[There is a] risk that underperforming building will be outed and owners, many of whom might not realize that they own an underperforming building, will be embarrassed,” Brooks says. “And so it’s important to do this at the right pace, and accompanied with incentives and information to enable the laggards to catch up.”
These concerns, he suggested, could potentially be addressed by keeping data disclosure internal for a year or so, beginning with commercial buildings before applying the bylaw to multi-residential buildings and starting with energy reporting before including water consumption, for which a widely accepted normalization strategy has yet to be developed.
Normalization — the ability to compare like with like — is another issue Brooks will be paying close attention to as the bylaw is developed.
“It’s not fair to suggest a building that houses Google servers is a bad building because it has high energy consumption,” he offers by way of example. “Google servers have got to go somewhere.”
Other factors to control for include whether a building has a call centre, a food court, an underground garage.
These considerations aside, Toronto’s large property owners are ready for energy reporting requirements, Brooks says.
“You could argue that a lot of the private owners are way out ahead of regulation on this because the market is demanding it,” he says. “The tenants are demanding highly functional sustainable space nowadays, and that’s why you see so many LEED Gold, and now LEED Platinum, buildings in downtown Toronto.”
The Canada Green Building Council (CaGBC) is the purveyor of LEED designations. The CaGBC’s Greater Toronto Area (GTA) chapter will participate in the city’s consultations. Ian Theaker, chair of the CaGBC GTA chapter’s advocacy committee, says local members voted last winter to make energy reporting one of three priority areas for action.
“We’ve got energy performance labels for refrigerators, for appliances, for lots of things in our life, and I think that the time has come for that to be reflected in buildings, as well,” he says, “which … typically [represent] the biggest investments we make in money, energy, materials, etc., as society and as individuals.”
In Theaker’s talks with the CaGBC GTA chapter’s members, as well as those in the building industry, the resources required to fulfill any benchmarking requirement have emerged as a key concern. And similarly to Brooks being concerned about immediate public disclosure and normalization, he believes building owners should be given the opportunity to share their stories — why their building is performing the way it is — alongside the raw data they report.
So far, though, the feedback Theaker has heard has largely been positive, with no one opposing the city’s move.
“The general reaction, particularly [from owners of] the Class A office spaces, is that mandatory reporting of the building energy and GHG emissions is coming down the pipes; it’s a question of when, not if,” says Theaker. “And so they’re interested, as are we, in making sure that it’s actually going to happen well and suits everyone’s needs.”
Michelle Ervin is the editor of Canadian Facility Management & Design.
