Ontario introduced its Energy and Water Reporting and Benchmarking (EWRB) regulation in 2017, becoming the first province to make information on building utility consumption more accessible.

In the beginning, EWRB only targeted buildings more than 250,000 square feet with an eye to include smaller buildings more than 50,000 square feet. Since COVID-19 struck, the reporting deadline was extended to October 1, 2020 for large buildings and with buildings between 50,000-100,000 square feet not needing to report until 2023. However, the roughly 10,000 Ontario buildings in this lowest bracket should consider reporting voluntarily as early as possible, especially at a time when stimulus money is expected to flow toward green recovery.

The provincial government had originally proposed exempting this tier of buildings altogether (and still might), thinking the change would lower compliance costs on businesses by about $300 per building annually. But this number dips well below the utility costs savings that the program could actually achieve. Data from other North American jurisdictions shows the average building in this size class would save between $1000 and $1500 per building after only one year of benchmarking.

It is a move that runs counter to the industry’s own need for data transparency. Buildings contribute up to 17 per cent of Canada’s greenhouse gas (GHG) emissions and up to half in large cities like Toronto. EWRB is an environmental regulation, but it is also good economic policy. While building codes and standards help regulate efficiency in new buildings, existing buildings have been operating with little oversight and, in fact, no insight at all into how energy and water was being used in our cities. This not only makes regulation impossible and utility planning difficult; it costs building owners a lot of money.

Utility benchmarking—the practice of comparing performance against a standard or peer group—is the best indicator of when a building is underperforming and wasting money. Making building performance data widely available provides valuable intelligence to condo corporations.

Missed Opportunities of Benchmarking

There is a learning curve for both condo corporations required to report and the utilities providing the data. But it will be better to start learning now, rather than in several years when it becomes mandatory and the data becomes public. The information generated can provide condo boards with the ability to track utility consumption over time and flag opportunities for improved energy and water efficiency sooner rather than later.

With the potential for stimulus funds directed at shovel-worthy building projects, including energy retrofits, this intelligence can help ensure that smaller building owners don’t lose ground competitively. Large building portfolios have a strategic advantage when it comes to deploying energy efficiency programs. They typically have more resources and access to capital and are already benchmarking and seeing the benefit to the bottom line. Individually owned buildings like condos are already less likely to participate in voluntary programs like Leadership in Energy and Environmental Design (LEED), Race to Reduce, BOMA BEST, and Utility DSM and CDM programs. With four years of voluntary reporting for smaller buildings, it is likely Ontario will see much lower compliance rates and lower uptake of conservation opportunities. These buildings will fall even further behind.

One critical issue still to be addressed is that those condo corporations that do choose to participate on a voluntary basis will be hindered because utilities won’t be required to provide individual unit meter data for the purpose of benchmarking, which they must do for buildings in the mandatory group. This will leave some buildings with separate meters at the mercy of the local utilities willingness to comply.

Cities across Canada are declaring climate emergencies. The federal government wants the country to become carbon neutral in 30 years. Buildings are expected to lead the way, and those buildings with good data are far less likely to be caught unprepared when the market or regulation demands lower emissions.

As Ontario—and indeed, all of Canada—looks ahead to this critical decade of climate action, there is no reason that buildings under 100,000 square feet should wait to participate in the EWRB and reaping the benefits inherent in data transparency.

Jeff Ranson is GTA regional director at the Canada Green Building Council. He supports green building market transformation in southern Ontario, consulting for numerous private and public sector organizations around capacity building and strategic planning for sustainable development and climate change mitigation.

Next Steps

The Canada Green Building Council (CaGBC) has provided recommendations for the Ontario government’s consideration:

• Continued roll-out of EWRB to buildings under 100,000 square feet. To minimize the cost of implementation, the government could consider a one-year delay for the third phase of EWRB to allow for further program refinement or delay until reaching a specific threshold, such as when 75 per cent of buildings over 100,000 square feet are reporting.
• Invest in capacity building and training for smaller buildings. Minor investments in training could unlock huge economic opportunity and potential energy cost savings, while helping support the development of skills training needed for Ontario’s construction workforce to take advantage of the low-carbon economy.
• Ensure the availability of whole-building utility data (including unit meters) to any building owners who wish to voluntarily participate in EWRB.