The Building Owners and Managers Association of the Greater Toronto Area’s (BOMA Toronto) recently published letter to the Ontario Ministry of Energy (MOE) offers nine recommendations on the draft policy of the province’s Green Button energy data analytics network.
The document, authored by Bala Gnanam, director of sustainable building operations & strategic partnerships, BOMA Toronto, supports Green Button as “an important tool for promoting compliance to impending Energy and Water Reporting and Benchmarking (EWRB) Regulation, under Bill 135, and for promoting better building performance in general.”
“We believe easy access to utility consumption data through Green Button would not only make it effortless for property managers and landlords to comply with EWRB regulation, but also the availability of real-time interval data would lead to greater understanding and management of energy use and subsequently impact the overall efficiency of the building and help drive down costs,” states Gnanam in the letter.
Recommendations to ensure the draft policy is fair, practical and meets the needs of the commercial real estate industry include:
Recommendation 1: The draft proposal should require all electricity, natural gas and water utilities and unit sub-metering companies to adopt both Green Button (GB) standard Download My Data and Connect My Data for commercial customers.
Recommendation 2: The draft proposal should require all electricity, natural gas and water utilities to use uniform billing format and provide consistent content (subject to type of utility) when invoicing its customers, and where applicable, provide a single bill containing all three utility types.
Recommendation 3: The draft proposal should consider implementing the GB standard through a single and integrated platform for each utility type hosted by a secure and regulated service provider.
Recommendation 4: The draft proposal should require/allow utility and application service providers to register their offer of services through a single platform, rather than registering separately with each utility.
Recommendation 5: The draft proposal should indicate that the entire process of implementation, support and maintenance of GB standard be managed by either MOE or by another single service provider who is thoroughly vetted and approved by MOE, with adequate oversight and governance.
Recommendation 6: The draft proposal should aim to phase-in GB implementations starting with Ontario’s CLD and water utilities of large Ontario cities, and mandate compliance by December 2017 – aligned with the end of Year 2 of the EWRB implementation.
Recommendation 7: MOE must work with NRCan to enable ESPM to become GB compliant and integrate Connect My Data to support EWRB.
Recommendation 8: MOE should create a special working group or a committee consisting of representatives from utilities, customers and energy service providers to discuss and agree on the interpretation of the GB standard. This group could also be tasked with drafting the format and defining the content for utility bills so that customer bills across Ontario will have the same format and content.
Recommendation 9: The draft proposal should require/allow a formal GB certification and seal for service providers, ensuring customers that these service providers have met all the technical and privacy requirements to provide GB solutions.
